Standard Interpretations - Table of Contents|
| Standard Number:||1910.94(b); 1910.215|
August 6, 1998
Mr. Peter H. Weiner
Law Offices of Paul, Hastings,
Janofsky & Walker LLP
345 California Street
San Francisco, California 94104-2635
Dear Mr. Weiner:
This is in response to your letter of January 7, addressed to Ms. Emily Sheketoff, former Deputy Assistant Secretary for Occupational Safety and Health Administration (OSHA), regarding the classification of 3M's Scotch-Brite surface conditioning wheels as polishing or buffing wheels rather than as abrasive grinding wheels. Your inquiry was forwarded to my office for response.
In your letter you indicated that 3M believes that it would be appropriate for OSHA to provide an interpretation to classify surface conditioning wheels as polishing or buffing wheels rather than abrasive grinding wheels. Abrasive wheels must be guarded in accordance with 29 CFR 1910.215. Section 1910.215 addresses the hazards of coming in contact with a rotating abrasive wheel and of being struck by abrasive wheel fragments. An abrasive wheel is defined in 1910.211(b)(14) as a cutting tool consisting of abrasive grains held together by organic or inorganic bonds. The hazard of inhaling particles during grinding, polishing, and buffing operations are covered under 1910.94(b). Polishing and buffing wheels are defined in 1910.94(b)(1)(xiii) as all power-driven rotatable wheels composed all or in part of textile fabrics, wood, felt, leather, paper, and may be coated with abrasives on the periphery of the wheel for purposes of polishing, buffing, and light grinding.
Scotch-Brite nonwoven surface conditioning wheels are used for surface conditioning, which is an operation that changes the surface of a work piece without removing or damaging the base material, not for cutting or bulk metal removal. Typical surface conditioning operations are