OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
July 22, 2010
Letter # 20090917-9271
Re: Hand-held gas-powered cut-off saws.
Question #1: Employees use hand-held gas-powered cut-off saws with abrasive blades to cut ductile iron pipe and then grind a bevel onto the cut end. Blade manufacturers specifically warn against this practice. Do OSHA construction standards prohibit this use of cut-off saws?
Yes, OSHA construction standards prohibit the use of the cut-off saw in the manner that you describe.
29 C.F.R. 1926.303 (Abrasive wheels and tools) provides:
(d) . . . All abrasive wheels and tools used by employees shall meet . . . applicable requirements of American National Standards Institute, B7.1-1970, Safety Code for the Use, Care and Protection of Abrasive Wheels.
ANSI B7.1-1970 provides, in relevant part:
9.9 Side Grinding. Side grinding shall only be performed with wheels designed for this purpose.
Grinding a bevel onto the end of a cut ductile iron pipe is side grinding, because the cutting is taking place perpendicular to the cut surface. Wheels on cut-off saws are not designed for side grinding (or lateral pressure); they are constructed for radial pressure only. Indeed, you indicate in your letter that blade manufacturers specifically warn against use of the cut-off saw in the manner you describe. Thus, using a cut-off saw to grind a bevel onto the end of a cut ductile iron pipe is contrary to ANSI B7.1-1970 and prohibited by 29 C.F.R. 1926.303(d).
We note that you are located in Arizona, which administers its own OSHA-approved state plan. Such a state is required by law to have a program of standards and enforcement that is at least as effective as the federal OSHA requirements. However, it may enact more stringent requirements. Employers in that state are then required to follow the state's more stringent requirements. For specific information on Arizona's interpretation and enforcement policy with regard to your question, please contact:
Arizona Division of Occupational Safety and Health
800 West Washington Street, 2nd floor
Phoenix, Arizona 85007
Phone: (602) 542-5795
Fax: (602) 542-1614
If you need further clarification on this subject, please contact us by fax at: U.S. Department of Labor, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Bill Parsons, Acting Director
Directorate of Construction