June 22, 1998
Gabriel J. Gillotti, Director
Office of Voluntary Programs
71 Stevenson Street
San Francisco, California 94105
Re: D'AX Blades; Abrasive wheels; 29 CFR §1926.303; §1910.215(b)(12)
Dear Mr. Gillotti:
This is in response to your November 13, 1997, memorandum to Roy Gurnham, former Director
of the Office of Construction Standards and Compliance Assistance, regarding whether D'AX
wheels should be considered cutting saw blades or abrasive wheels. The significance of the
question is that different guarding requirements apply depending on whether the product
would be considered an abrasive wheel.
Cal/OSHA received a letter on December 17, 1996, from Mr. Jim Nicholson, Product Manager for
Diamond Systems, Inc., Ontario, Canada. This letter requested an interpretation and
clarification of the guarding requirements that apply to electric and gasoline powered
hand held saws when equipped with the D'AX line of wheels. In a January 8, 1997, response
to D'AX, Cal/ OSHA stated that the product would be considered an abrasive blade. You ask
if the Occupational Safety and Health Administration agrees with Cal/OSHA's classification.
The definition of an abrasive wheel, as defined by CFR §1910.211(b)(14) and American
National Standards Institute (ANSI) B7.1-1970, is "a cutting tool consisting of abrasive
grains held together by organic or inorganic bonds." We have examined both the product
literature and the 12" blade that you submitted. The D'AX wheel is constructed with bonded,
steel fragments arranged in intermittent clusters around the periphery of a steel disc. The
disc is about 1/4" thick. The steel fragments are too large and sharp to be considered
abrasive grains. The fragments remove material primarily by severing rather than by abrasion.
Because of the cutting action, when used in a portable power tool in construction, this
product must be guarded as a cutting saw. The guarding requirements are in 29 CFR
§1926.300(b). The required configuration of the guard, including the extent to which
it must cover the wheel, depends on the type of equipment with which the wheel is used
and on the operation being performed. This standard prescribes the minimal guarding
required when operating a tool utilizing the D'AX wheel. Any additional guarding that
would further protect an employee from possible injury, without creating a greater
hazard, is encouraged.
If you require further assistance, please do not hesitate to contact us again by writing to:
Directorate of Construction- Office of Construction Standards and Compliance Assistance,
Room S-1506, 200 Constitution Avenue, N.W., Washington, D.C. 20210.
Russell B. Swanson, Director
Directorate of Construction