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When magazine-fed powder-actuated tools are loaded

Summary OSHA was asked how its powder-actuated tool rules apply to a tool with a magazine of explosive power loads. The agency said the rules had not contemplated that design and that, for inspection, the tool is not considered loaded until the magazine feeds a load into it. OSHA said it planned to issue a program directive on the subject.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-09-02
Date issued
September 2, 1975
Status
Active
Status last verified October 10, 2026

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September 2, 1975

MEMORANDUM FOR: EDWARD E. ESTKOWSKI
ATTENTION: HAROLD I. WHITE
Subject: Request for Interpretation - 1926.302(e), Powder Operated Handtools

This is in response to your memorandum of June 23, 1975, with attached material from Hilti, Inc., regarding an interpretation of 1926.302(e)(5) and (6). In addition, this confirms Jeff Campbell's phone call of July 18, 1975.

In developing and promulgating 29 CFR 1926.302(e) Powder-actuated tools, the magazine or clip-fed explosive power load was not considered. This is a magazine containing several explosive power loads which is inserted into the tool and single loads are fed into the ram (firing chamber) as needed.

Our information indicates that, in addition, the following standards did not address magazine-fed explosive power loads:

ANSI A10.3-1970 safety requirements for explosive-actuated fastening tools.

29 CFR 1910.243(d) Explosive actuated fastening tools

29 CFR 1915.75 Powder actuated fastening tools

29 CFR 1916.75 Powder actuated fastening tools

When magazine-fed tools are inspected, the tool is not considered loaded until the magazine feeds the tool.

An OSHA Program Directive #100 series will be issued to cover this subject.

Barry J. White
Associate Assistant
Secretary for Regional Programs

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