Tool safety requirements

No — under 1918.69(a) employers must not issue or permit the use of visibly unsafe tools.

• Inspect tools before issuing or permitting use and immediately remove from service any tool that is visibly cracked, broken, frayed, missing guards, or otherwise damaged.
• Train workers to report unsafe tools and establish a tagging/lockout or removal procedure so unsafe tools cannot be used.

Cited: 1918.69(a).

Portable hand-held electric tools must have a switch that the operator must manually hold in the closed position for the tool to run, so the tool stops when the operator releases the control. This is required by 1918.69(b)(1).

• This type of "constant-pressure" or "dead-man" switch prevents the tool from running unattended and reduces the risk of loss of control injuries.
• If a tool does not have this type of switch, remove it from service or retrofit it only with the manufacturer’s written approval or an engineer’s review if required by other standards.

Cited: 1918.69(b)(1).

All portable, power-driven circular saws must have upper and lower guards covering the blade to the depth of the teeth except where a minimal arc is needed for bevel cutting or retraction; the lower guard must automatically and instantly return to cover the blade when withdrawn from the work, as required by 1918.69(b)(2).

• Upper guard: covers the saw to the depth of the teeth, except for the small arc needed to tilt the base for bevel cuts.
• Lower guard: must cover the saw to the depth of the teeth except for the minimum arc needed for retraction and contact; it must automatically and instantly return to the covering position when the saw is withdrawn.
• If a guard is missing or not working properly, take the saw out of service until repaired or replaced.

Cited: 1918.69(b)(2).

No — employers must not issue or permit the use of visibly unsafe tools; offering a visibly unsafe tool for use because you "intend to repair it later" is not allowed under 1918.69(a).

• Repair tools before issuing them for use; if immediate repair isn’t possible, remove the tool from service and provide a safe replacement.
• Maintain a documented inspection and maintenance program so tools are kept in safe working order and visibly unsafe tools are identified and removed promptly.

Cited: 1918.69(a).

No — portable hand-held electric tools must be equipped with a switch that requires the operator to hold it closed for operation, per 1918.69(b)(1); modifying a tool to bypass that requirement creates an unsafe condition and is not permitted.

• Any modification that defeats or bypasses safety switches should be avoided; removal of a required operating control may lead to citations and increased injury risk.
• If a different switch is necessary for a specific, justified task, obtain the tool manufacturer’s written approval or equivalent engineering documentation before altering controls.

Cited: 1918.69(b)(1).

Inspect the lower guard to confirm it covers the blade to the depth of the teeth except for the minimal arc needed for work and that it automatically and instantly returns to the covering position when the saw is withdrawn, as required by 1918.69(b)(2).

• Check for physical damage, binding, debris, or corrosion that prevents free, automatic movement.
• Test the guard by running the saw (with appropriate safeguards) and withdrawing it from the work to verify the lower guard snaps back instantly.
• Tag and remove saws from service if the lower guard is damaged, slow, or does not return automatically; repair by a qualified person before returning to service.

Cited: 1918.69(b)(2).

Both the worker and the employer share responsibility: workers must report or stop using visibly unsafe tools and employers must not issue or permit their use under 1918.69(a).

• Employers should train workers to recognize visible hazards (broken guards, frayed cords, cracked housing) and how to report or tag out unsafe tools.
• Employers must act on reports and remove or repair unsafe tools before allowing further use.

Cited: 1918.69(a).

Employers must provide required personal protective equipment (PPE) at no cost when PPE is required by OSHA standards; the general employer-payment rule applies to maritime standards in Parts including 1918. The issue of employer payment for PPE is discussed in OSHA's interpretation on payment methods (see Employee PPE payment methods).

• If a specific longshoring task requires PPE, the employer should supply it and cannot shift that cost to the employee except for certain limited exceptions described in OSHA's PPE payment rule.
• Maintain records and policies showing PPE is provided and replaced as needed for tool use.

Cited: 1918.69 and OSHA interpretation Employee PPE payment methods.

You must not perform modifications that affect safety or capacity without the manufacturer's prior written approval or a qualified engineer’s written approval when the standard requires it; this principle appears in maritime LOIs about vehicle modifications and applies when tool modifications could affect safe operation. See the strobe light LOI at https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0 and 1918.69.

• Before modifying electrical or mechanical safety features (switches, guards), obtain manufacturer written approval or a qualified engineer’s approval if the change could affect safety.
• Document approvals and retrain operators if the modification alters operation or control patterns.

Cited: 1918.69 and OSHA LOI Strobe lights on industrial trucks.

No — 1918.69(b)(2) requires an upper guard that covers the saw to the depth of the teeth except only for the minimum arc necessary to tilt the base for bevel cuts; removing the upper guard for visibility is not permitted.

• If a particular operation truly requires a limited exposure, use a tool designed for that task with equivalent safeguards, and obtain manufacturer guidance.
• Never operate a saw with missing or disabled guards; remove the saw from service if guards are absent or not functioning and provide a safe alternative.

Cited: 1918.69(b)(2).

If a circular saw’s lower guard does not automatically and instantly return to the covering position, the employer must remove the saw from service until it is repaired, because 1918.69(b)(2) requires automatic instant return of the lower guard.

• Tag out the saw and prevent use until a qualified person fixes the mechanism.
• After repair, test the guard’s automatic return under controlled conditions before returning the saw to service.

Cited: 1918.69(b)(2).

Yes — the switch requirement in 1918.69(b)(1) applies to portable hand-held electric tools generally, which includes battery-powered cordless tools: they should be equipped with a switch that must be manually held closed to operate.

• For cordless tools, ensure the switch design stops the tool when released; if the switch can latch "on," evaluate whether that defeats the standard and consult the manufacturer for compliant models.
• Train users on proper operation and removal from service if a switch is faulty.

Cited: 1918.69(b)(1).

Employers should train workers to recognize required guards and switch types, to use tools only with intact guards and proper switches, and to report or stop work if a tool is visibly unsafe as required by 1918.69(a) and the portable tool requirements in 1918.69(b).

• Cover what to inspect before use (guards, switch operation, cords/batteries), safe operating practices, and how to tag/remove unsafe tools.
• Provide refresher training when tools change (e.g., after a modification approved per manufacturer/engineer guidance).

Cited: 1918.69(a) and 1918.69(b).

If a required guard is not available from the manufacturer, the employer must ensure an equivalent protective measure is used and document the steps taken to make the tool safe; do not allow use without adequate guarding under 1918.69(a).

• Contact the manufacturer for retrofit options; if the manufacturer cannot provide a guard, obtain written approval from a qualified Registered Professional Engineer after a safety analysis, similar to the approach described in the strobe-light LOI when modifications affect safety (https://www.osha.gov/laws-regs/standardinterpretations/2004-12-21-0).
• Until an adequate guard or equivalent control is in place, remove the tool from service and provide a safe alternative method.

Cited: 1918.69(a) and OSHA LOI Strobe lights on industrial trucks.

Yes — tools with frayed or damaged power cords are considered visibly unsafe and must not be issued or permitted for use under 1918.69(a). Remove the tool from service until the cord is repaired or replaced by a qualified person.

• Tag the tool as "Do Not Use," repair with manufacturer-approved parts or replacement cord assemblies, and verify insulation and grounding before returning to service.
• Consider using ground-fault protection or double-insulated tools where appropriate to provide added protection.

Cited: 1918.69(a).

OSHA does not universally require a latch on every sling hook in the slings standard, but it requires that slings be securely attached to their loads under maritime rules, and OSHA often expects latch-equipped hooks where needed to prevent accidental disengagement — see the safety latch LOI at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0 and related longshoring provisions cited there (e.g., 29 CFR 1918.66(e)(2)).

• Use latch-equipped hooks wherever the application makes latch use practical to prevent accidental load release.
• Where the hook application makes a latch impractical, use alternative positive attachments (shackles, bridles) as required by other longshoring provisions.

Cited: OSHA LOI Safety latches on sling hooks and 1918.69.