January 13, 1992
MEMORANDUM FOR: JAMES J. CONCANNON, DIRECTOR
OFFICE OF VARIANCE DETERMINATION
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
Subject: Interpretation of Multi-piece Rim Wheel standards at 29
CFR 1910.177
As requested, the correspondence file on Mi-Jack Products has been reviewed.
Mi-Jack Products seeks Occupational Safety and Health Administration (OSHA)
concurrence that the method, as demonstrated on their video cassette tape, of
mounting tires on multi-piece wheels complies with OSHA standards.
The method demonstrated by Mi-Jack Products is intended for use when servicing
tires on multi-piece rim wheels which are mounted dually. Mi-Jack Products
contends that their servicing procedures which include orientation of the
multi-piece wheel so that the locking rings face each other provide equal or
greater safety than provided by the servicing procedures and the engineering
control, that is, restraining device required by 29 CFR 1910.177.
The video cassette tape provided by Mi-Jack Products demonstrates that the
opposite tire contains the locking ring, tube and liner during an explosion
separation of a multi-piece rim wheel. However, the method demonstrated by
Mi-Jack Products does not provide equal or greater safety compared to the
requirements of 29 CFR 1910.177 which include not only safe procedures but also
a restraining device which, by definition, constrains all rim wheel components
including wheel components as well as the tire, tube and liner. The method of
mounting tires may not contain all rim wheel components. For example, pieces of
an exploded tire may deviate from paths which are perpendicular to the
assembled position of the rim wheel. An employee nearby, for example, standing
behind the trunk may be hit by flying tire fragments.
OSHA Standard Interpretation and Compliance Letters - Table of Contents
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