Rim wheel servicing requirements

Under 1915.94, shipyard employers must follow the same rim-wheel servicing requirements that appear in 29 CFR 1910.177 for servicing multi-piece and single-piece rim wheels. See 1915.94 and the identical 1910.177 requirements.

• This means the servicing rules that apply in general industry under 1910.177 also apply to shipyard employment under 1915.94.
• For the exact procedures, safe-work requirements, and definitions (for example, what constitutes multi-piece rims), consult 1910.177.

Under 1915.94, the rim-wheel servicing requirements do not apply to automobile tires or truck tires designated "LT." See the scope language implemented from 1910.177(a)(1) as adopted by 1915.94 and the OSHA interpretation addressing scope.

• OSHA has stated that 29 CFR 1910.177 applies to large-vehicle rim wheels (e.g., trucks, tractors, trailers, buses, off-road machines) and does not apply to ordinary automobile tires or truck tires labeled "LT." See Scope of rim wheel servicing.

Under 1915.94, C-type European Commercial Metric light truck tires can be treated as covered by the rim-wheel servicing rules; OSHA confirmed they can fall under 29 CFR 1910.177 (which 1915.94 adopts). See OSHA’s interpretation on C-type tires at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01.

• OSHA’s response said that C-type tires are similar to traditional "LT" tires and that coverage under 29 CFR 1910.177 is appropriate in many situations. Employers should evaluate whether the installation, use, servicing methods, and required equipment are substantially similar to "LT" tires. See the Scope of rim wheel servicing interpretation for details.

Under 1915.94, an employer’s differing method for servicing C-type tires may be treated as a de minimis condition in some cases, but that determination is fact‑specific. See OSHA’s interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 and the adopted requirement in 1915.94.

• "De minimis" means the employer used a measure different from the standard that has no direct or immediate relationship to safety or health.
• Whether a condition is de minimis depends on the specific installation, use, servicing methods, and equipment; employers should document the basis for any alternative practice and consult the cited interpretation if uncertain.

Under 1915.94, the specific procedures and technical details for safe rim-wheel servicing are the same as those in 29 CFR 1910.177, so you should consult 1910.177 for the full requirements; 1915.94 adopts those requirements for shipyard employment.

• Use 1910.177 for detailed steps, tools, and safety controls required when servicing multi-piece and single-piece rim wheels.
• If you are unsure how a provision applies to a specific tire type or operation, review OSHA interpretations such as the Scope of rim wheel servicing for clarifying guidance.

Under 1915.94, employers in States with OSHA‑approved State Plans must follow that State’s standards and enforcement, which may be more stringent than federal rules. OSHA’s rim‑wheel servicing coverage note and interpretation remind employers that State Plans can have different requirements; see 1915.94 and the Scope of rim wheel servicing interpretation.

• If you operate in a State Plan state, check with that State agency for any additional or stricter requirements.
• Federal OSHA guidance and interpretations (for example, the C‑type tire letter) explain federal positions but do not override a State Plan’s stricter rules.

Under 1915.94, if rim‑wheel servicing creates a potential for head injury from falling objects or overhead hazards, the employer must provide and require head protection under OSHA’s head‑protection rules. See the general head protection requirement in 1910 and OSHA’s interpretation on crane operators and head protection at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

• OSHA requires protective helmets where there is a potential for head injury from falling objects; employers must assess the workplace and require helmets if overhead hazards exist.
• The head protection interpretation explains that employers must provide helmets that meet ANSI Z89.1 consensus standards when hazards warrant it.

Under 1915.94, when you need to energize machinery temporarily to test or position a component, you may remove lockout/tagout devices only under the procedures allowed by OSHA’s control‑of‑hazardous‑energy standard; employers must follow the sequence and employee‑protection steps in 29 CFR 1910.147 as explained in OSHA’s interpretation on the minor servicing exception (see https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21).

• The temporary re‑energization steps include clearing tools and materials, removing employees from danger areas, removing devices as specified, energizing for the minimum time needed, and then de‑energizing and reapplying controls if further servicing is required. See the minor servicing interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.
• Always document and follow your energy‑control procedures when testing or positioning equipment during servicing.

Under 1915.94, servicing rim wheels on pickup trucks and vans is not generally covered if those vehicles use ordinary automobile tires or tires designated "LT," because 29 CFR 1910.177 (which 1915.94 adopts) excludes automobile tires and "LT" truck tires. See 1910.177(a)(1) and the Scope of rim wheel servicing interpretation.

• If a pickup or van uses a C‑type tire or a nonstandard wheel/tire assembly that behaves like larger commercial tires, OSHA’s interpretation says those situations should be evaluated case by case; C‑type tires may be treated as covered in many circumstances. See https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01.

Under 1915.94, adopting a different servicing method than a specific provision in 29 CFR 1910.177 will not automatically lead to a citation if the difference is a true de minimis condition or does not directly affect safety or health; however, whether it is de minimis is a fact‑specific determination. See the C‑type tire interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 and the adoption of 1910.177 by 1915.94.

• Employers should ensure alternate methods provide equivalent protection or otherwise document why a different method does not increase risk.
• If there is any question, consult OSHA guidance or the State Plan authority (if applicable) to confirm whether an alternative practice is acceptable.