Standard Interpretations - Table of Contents
• Standard Number: 1910.244(b); 1926.302(b)(10)

May 30, 2012

Mr. Thomas E. Enger
Clemco Industries Corp.
One Cable Car Drive
Washington, MO 63090

Dear Mr. Enger:

Thank you for your letter, dated December 22, 2011, to the Occupational Safety and Health Administration (OSHA). This letter constitutes OSHA's interpretation only of the requirements discussed in your correspondence and the subsequent email and telephone communications and may not be applicable to any question not delineated by that communication.

Your paraphrased scenario, question, and our replies follow:

Scenario: Clemco Industries sells abrasive blast cleaning nozzles that are covered under OSHA 29 CFR Part 1910 and 29 CFR Part 1926.

You stated that a European version of this valve operator is fitted with a hold-open, "ball and chain" device, whereby the ball is pushed into place to mechanically hold (block) the valve in the open position. A short chain, which is attached to the ball, is wrapped around the operator's wrist. If the employee releases his or her hold, the ball easily pulls free, causing the valve to close. Further, you stated that Clemco manufactures a modified version of its standard operating valve for use and distribution in the European market, which is fitted with a washer-and-chain and works similar to the ball-and-chain feature described above. Moreover, these self-releasing, ball-and-chain and washer-and-chain solutions may discourage the use of zip ties or a Velcro straps, and allow operators to remove their hands from the operating valve during blasting operations without shutting off the flow of the compressed air media.