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OSHA 1917.51

Hand tool safety requirements

Subpart C

14 Questions & Answers
10 Interpretations

Questions & Answers

Under 1917.51(a), what does “Hand tools used by employees shall be maintained in safe operating condition” require employers to do?

Employers must keep hand tools in safe working order and take defective tools out of service until repaired or replaced.

  • Inspect hand tools regularly and before use for damage (broken handles, mushroomed heads, cracked housings, frayed cords, etc.).
  • Repair or replace tools that are unsafe; tag or remove them from service while awaiting repair.
  • Train employees to report damaged tools and to use the correct tool for the job.

For the regulatory requirement, see 1917.51(a).

Under 1917.51(b)(1), must a hand-held portable electric tool’s switch be held down the whole time the tool is running?

Yes. Hand-held portable electric tools must have switches that are manually held closed for the tool to operate, so the operator must hold the switch to keep the tool running.

  • This prevents the tool from remaining powered if the operator releases it accidentally.
  • Do not use devices that lock the switch on in place of the required manual-hold switch for hand-held portable tools.

See the specific requirement at 1917.51(b)(1).

Under 1917.51(b)(2), what guards are required on portable power-driven circular saws?

Portable power-driven circular saws must have both upper and lower guards, with the upper guard covering the saw to the depth of the teeth except for the minimum arc needed to tilt the base for bevel cuts, and the lower guard covering the saw to the depth of the teeth and automatically returning to cover the blade when withdrawn from the work.

  • The lower guard must automatically and instantly return to the covering position when the tool is not engaged with the work.
  • The upper guard can be reduced only to the minimum arc necessary for bevel cuts.

This is required by 1917.51(b)(2).

Under 1917.51(b)(2), is it acceptable to disable or remove the lower guard on a portable circular saw for certain cuts?

No. The standard requires the lower guard to cover the saw to the depth of the teeth except for the minimum arc needed for retraction during cutting, and it must automatically and instantly return to the covering position when the tool is withdrawn from the work. Disabling or removing that guard is not compliant.

  • Temporary bending or tying of the lower guard so it won’t return is not allowed.
  • If a cut requires a different tool or guard design, use an appropriate tool or approved modification rather than defeating the lower guard.

Reference: 1917.51(b)(2).

Under 1917.51(b)(2), how much of the blade can the upper guard expose when tilting the saw for bevel cuts?

The upper guard may expose only the minimum arc necessary to permit the base to be tilted for bevel cuts; otherwise the upper guard must cover the saw to the depth of the teeth.

  • Keep the exposed arc as small as possible and only for the specific adjustment or cutting operation.
  • If the manufacturer provides a bevel-tilt guard design, follow that design and the manufacturer's instructions.

See the wording in 1917.51(b)(2).

Under 1917.51(c), can employees use pliers, wrenches, or a hammer to cut metal strapping or banding used to secure cargo?

No. Only proper cutting tools are permitted to cut metal strapping or banding used to secure cargo; using pliers, wrenches, hammers, or other non-cutting tools to sever banding is not allowed.

  • Use banding cutters, snips, or other tools designed for cutting metal strapping to avoid flying pieces, uncontrolled recoil, and injury.
  • Ensure cutting tools are maintained in safe operating condition per [1917.51(a)].

See 1917.51(c).

Under 1917.51(b)(1), does the manual-hold switch requirement apply to bench-mounted or stationary electric tools?

No. The requirement in 1917.51(b)(1) specifically covers hand-held portable electric tools; bench-mounted or stationary tools are not described by this subsection and may be governed by other standards or machine-guarding requirements.

  • For stationary equipment, follow applicable machine-guarding and electrical safety rules and manufacturer instructions.
  • When in doubt, consult the broader marine terminals standard 1917 or other relevant OSHA requirements for stationary machinery safety.

Under 1917.51(a), how should employers document or act on routine inspections of hand tools when the standard does not give specific inspection frequencies?

Employers should establish and follow a reasonable inspection and maintenance program that ensures hand tools remain in safe operating condition, because 1917.51(a) sets a performance-based requirement without specific frequencies.

  • Base inspection frequency on tool type, usage rate, environment, and manufacturer guidance (for example: daily checks for frequently used tools, periodic formal inspections for others).
  • Keep records or logs when appropriate, remove defective tools from service, and train employees to recognize and report hazards.

See the performance requirement in 1917.51(a).

Under 1917.51(b)(2), what must happen when a portable circular saw’s lower guard retracts to make contact with the work?

When the lower guard retracts to allow the blade to contact the work, it may do so only to the minimum arc necessary for proper retraction and contact, and it must automatically and instantly return to the covering position when the tool is withdrawn.

  • The guard’s retraction must be limited to allow cutting and must not leave the blade exposed when the saw is not cutting.
  • Ensure guards are not obstructed and are functioning as intended; repair defective guard mechanisms immediately.

See the requirements at 1917.51(b)(2).

Under 1917.51(b)(1), are tools with a locking-on switch permitted for hand-held portable electric tools used by employees?

No. Hand-held portable electric tools must be equipped with switches that must be manually held in a closed position to operate the tool, so a lock-on that allows the tool to run without continually holding the switch would not meet 1917.51(b)(1).

  • If a specific handheld tool is designed for continuous operation with a different switching mechanism, consult the manufacturer and evaluate whether it remains a hand-held portable tool or if other standards apply.
  • Do not circumvent the manual-hold requirement by adding devices that defeat the intended safety function of the switch.

Under 1917.51(b)(2), who is responsible for ensuring portable circular saw guards comply and work correctly on a marine terminal site?

The employer is responsible for ensuring portable circular saws on site have the required upper and lower guards and that those guards function as required by 1917.51(b)(2).

  • Employers must provide compliant tools, inspect and maintain guards, and remove or repair saws with defective guards.
  • Employers should train employees on safe use including guard function checks before use.

Refer to the marine terminals standard 1917.51(b)(2).

Regarding applicability: does 1917.51 apply at a designated waterfront facility used solely for bulk storage and transfer of liquids or gases?

No; Part 1917’s specific requirements, including 1917.51, do not apply to facilities that meet the definition of a "designated waterfront facility" used solely for bulk storage, handling, and transfer of liquids or gases, as explained in OSHA’s Letter of Interpretation on applicability to waterfront facilities.

  • If your facility is a designated waterfront facility as described in the Letter of Interpretation, consult that interpretation for applicability details.

See the OSHA Letter of Interpretation: Applicability to waterfront facilities (May 31, 2017) and the Part 1917 overview.

Under 1917.51(c), what are examples of acceptable cutting tools for metal strapping or banding used to secure cargo?

Acceptable cutting tools are those specifically designed to cut metal strapping or banding, such as banding cutters, metal snips, or shears made for that purpose. Only tools intended for cutting metal strapping should be used.

  • Avoid improvised techniques (prying, hammering, bending) that can cause the strapping to recoil or send sharp fragments flying.
  • Maintain cutting tools in safe operating condition per 1917.51(a).

Requirement: 1917.51(c).

Under 1917.51(a), what should an employer do if an employee reports a portable electric tool has a frayed cord or damaged switch?

The employer must take the tool out of service and repair or replace it before it is used again to ensure it is maintained in safe operating condition.

  • Tag or remove the defective tool, document the issue, and arrange for repair or replacement.
  • Retrain or remind employees to inspect tools before use and to report hazards promptly.

See the maintenance requirement at 1917.51(a).