Interpreting OSHA

When Congress passed the Occupational Safety and Health (OSH) Act in the early 1970s, the goal was to improve safety for American workers

When Congress passed the Occupational Safety and Health (OSH) Act in the early 1970s, the goal was to improve safety for American workers. Eventually, the OSH Act led to standards for specific industries that were considered particularly hazardous. The practice of servicing “split rims” had caused a number of serious and fatal accidents, so the Occupational Safety and Health Administration (OSHA) created a standard for the tire industry that would establish safety procedures for all workers who handled these assemblies.

I've spent the better part of my 27-year career training truck tire technicians, so I've become intimately familiar with OSHA Standard 29 CFR 1910.177. In fact, I often find myself offering interpretations of the standard. One area that seems to be particularly popular is training. The standard specifically states that any employee who “services” a truck tire must be trained to recognize the hazards and follow the safety procedures outlined in the regulation. Since the OSHA definition of service includes demounting, mounting, inflating, deflating, installing, removing and handling, any employee who performs even one of those acts must be trained.

For some reason, too many fleets believe the rule only applies to tire dealers so they fall short on their obligation to provide training for technicians because they don't do tire work. And the confusion only grows when they find out that the mechanics who install and remove truck tires to work on the brakes, front end or suspension must still be trained to demount and mount tires even though they've never used a tire iron. But OSHA clearly states who must be trained and what the training must cover, so there shouldn't be much interpretation needed.

There is another section of the standard that is left open to interpretation, however, and fleets will get a variety of answers when faced with this question: “Is torque required by OSHA?” First of all, I need to make it clear that the word torque does not appear anywhere in 1910.177 nor are there any guidelines for the installation and removal of truck tire and wheel assemblies. On the other hand, the standard does mention a rim manual that contains the maintenance and safety procedures for the type of wheel/rim being serviced. The training requirements state that the training must cover the information contained in the rim manual.

I've always been one to err on the side of caution, so I say that since 1910.177 requires technicians to follow the procedures outlined in the rim manual, then torque is required by OSHA because every rim manual includes the installation torque. Again, it's just my opinion, but I've been involved in enough OSHA investigations and lawsuits to know that OSHA investigators and plaintiffs' attorneys are known for making broad interpretations of regulations and industry guidelines, especially when a serious or fatal incident is involved.

Wheel-off accidents continue to claim the lives of motorists throughout North America. Even though the statistical average remains a minute fraction of the total truck tire and wheel population, the level of devastation that occurs when a 200-lb. tire assembly strikes an oncoming vehicle is guaranteed to receive ample media coverage. Fortunately, the industry has been spared any major investigative reports on truck tire and wheel installation, probably because few people understand that the practice of using an impact wrench to make sure each lug nut is “good and tight” is not consistent with any rim manual in existence.

Let's hope the industry does something about it before the cameras start rolling.

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