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 https://www.osha.gov.

November 15, 1999

Jeff Haenisch
Avoca Village Sales
182 Cessna Street
Avoca, NY 14809

Dear Mr. Haenisch:

Thank you for your August 31, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Compliance Programs. You requested an interpretation of the standards regarding fire departments' usage of wood cutting/toothed blades on portable abrasive machines, commonly known as cut-off machines. Although fire department members are usually local government employees not subject to federal OSHA requirements, the State of New York has an approved state plan which covers public employees. The State of New York has adopted the federal safety and health standards.

It is important to note that the machines you describe are designed by manufacturers for use only with abrasive wheels in good condition. A cutoff saw whose abrasive blade has been replaced with a wood cutting blade becomes the functional equivalent of a circular saw, for which blade guarding requirements are set forth at 1910.243(a)(1)(i). Guarding would have to be provided for both the upper and lower portions of the blade.

Since there are many different configurations of these machines and possible modifications, end users (employers and employees) would have to rely on guidance from several sources for the design, construction, and use of the guarding system. These sources may include:

  • The manufacturer's requirements and recommendations;
  • ANSI 01.1-1961, Safety Requirements for Woodworking Machinery;
  • 1910.243(a)(1)(i)-Guarding of Portable Powered Circular Saws;
  • 1910.212-General Machine Guarding Requirements for all Machines;
  • 1910.213(r)(4)-Woodworking Machinery Requirements;
  • Section 5(a)(1) of the Occupational Safety and Health Act.

There is, however, a more fundamental problem with the practice of using a toothed blade in a cutoff saw. Replacing an abrasive wheel on a cutoff machine with a wood cutting saw blade of equal diameter could result in a surface feet-per-minute speed which is in excess of the saw blade manufacturer's design specifications. This can result in greatly increased reactive forces which could cause the operator to lose control of the saw. The likelihood of catastrophic failure of the saw blade is also increased. Either event could result in serious physical harm or death to the operator.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of General Industry Compliance Assistance at 202-693-1850.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs