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Guarding internal-work abrasive grinding wheels

Summary A manufacturer asked whether an abrasive wheel needed a guard while performing internal work inside the workpiece. OSHA said the cited machine-guarding rules expressly excepted that situation because the workpiece provided equivalent protection, provided the standard's intent was met. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-01-24-0
Date issued
January 24, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 12, 2026
Topics
Workplace Safety OSHA 1910 Machine Guarding Grinders
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 24, 1996

Mr. John P. Coniglio, CHMM, RPIH
Executive Vice President - Operations 3320
N. Benzing Road
Orchard Park, NY 14127
Dear Mr. Coniglio:

This is in response to your letter of October 27, 1995 addressed to Mr. Don Kallstrom related to hand portable operated abrasive grinders, and in follow-up to an interim phone call placed to you on January 19, 1996. You requested an interpretation on whether machine guards are required when a wheel is used for internal work while within the work being ground.

Under paragraphs 29 CFR 1910.215(a)(i) and 1910.243(c)(1)(i)(a), the standard excepts from the general requirements for machine guarding "wheels used for internal work while within the work being ground." The intent of the exception, as your letter correctly stated, is that the work piece is offering equal protection and a guard would not be needed given the general parameters of your scenario. No 1910 or 1926 citation would be issued as long as the intent of the standard is met.

If we can be of any further assistance, please contact Margo Daniel of my staff on (202)219-8041.

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

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