Industrial Board v. Hilti Rapid Fastening Systems, Inc.

28 Pa. D. & C.2d 11, 1962 Pa. Dist. & Cnty. Dec. LEXIS 122
CourtPennsylvania Court of Common Pleas, Dauphin County
DecidedMay 28, 1962
DocketCommonwealth docket, no. 569
StatusPublished
Cited by1 cases

This text of 28 Pa. D. & C.2d 11 (Industrial Board v. Hilti Rapid Fastening Systems, Inc.) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Dauphin County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Industrial Board v. Hilti Rapid Fastening Systems, Inc., 28 Pa. D. & C.2d 11, 1962 Pa. Dist. & Cnty. Dec. LEXIS 122 (Pa. Super. Ct. 1962).

Opinion

Herman, J.,

We have before us in this matter an appeal by Hilti Rapid Fastening Systems, Inc., sometimes called Hilti, Inc., (but hereinafter referred to as “Hilti”), from an order of the Industrial Board, in the Department of Labor and Industry, of the Commonwealth of Pennsylvania, directing Hilti to discontinue sales of the “Hilti DX 100-L” powder actuated tool until certain modifications in its design are made and approved, and further directing that the use of this tool be discontinued in this Commonwealth.

Pursuant to provisions of the Act of June 2, 1913, P. L. 396, sec. 14, 71 PS §1443, and to the provisions of the Act of May 18, 1937, P. L. 654 sec. 12, 43 PS §25-12, sometimes called the General Safety Law, regulations governing operation of powder actuated tools were adopted and were promulgated and made effective as of May 22,1958, by the Secretary of Labor and Industry.

The General Safety Law provides, in part, in section 2(g) (43 PS §25-2 (g)) :

“All building construction . . . shall be conducted in a manner as to avoid accident hazards to workers or the public . . . [Equipment used in such opera[13]*13tions, shall be designed, manufactured, constructed, and erected as to be safe for the purpose intended. . . ”

The regulations referred to above which initially have a bearing on the case at hand are these:

“SECTION 4. GENERAL REQUIREMENTS
“Rule 1. Approval of Equipment
“(a) No powder actuated tool shall be operated or used within this Commonwealth unless:
“1. the tool, including protective shield and all accessories pertaining thereto, shall be of an approved type; ... * * * *
Rule 3. Safety Precautions
“(a) Protective Shield. Powder actuated tools shall not be used without an approved protective shield or muzzle attachment appropriate for the particular tool and designed to confine flying particles and minimize the possibility of ricocheting of studs, pins, or fragmentation, property attached thereto. Only those tools shall be used which cannot be fired without the protective shield, muzzle attachment or guard in proper place.
“(b) Special Protective Shield. Where a standard shield or guard cannot be used, or where it does not cover all apparent avenues through which flying particles might escape, a special approved shield or guard fixture of the jig, designed and. built by the manufacturer of the tool being used to provide this degree of protection, shall be used as a substitute.
if if if if
“(d) Tool Position. The tool shall be perpendicular to the material being penetrated at the time of firing, except when protected in accordance with Rule 3— Paragraphs (a) and (b).
if if if if
“SECTION 5. SPECIAL REQUIREMENTS FOR MANUFACTURERS
[14]*14“Rule 7. Safety Locks
“(a)Powder Actuated Tools shall be provided with safety locks so designed that failure of any part of the tool or lock will cause the tool to be in an inoperative position. The lock shall also be designed so that it can only be manually set and cannot get into firing position through fall or other accidental occurrence.
*x* * *
“Rule 9. Firing Position
“(a) The firing mechanism shall be so designed that the tool cannot fire during loading or preparation to fire, or if the tool is dropped while loaded. Firing of the tool shall be dependent upon at least two separate and distinct operations of the operator, with the final firing movement being separate from the operation of bringing the tool into the firing position. These requirements provided for in this rule are in addition to those required by Rule 7.
“(b) The tool shall be so designed as not to be operable other than against a work surface and unless the operator is holding the tool against the work surface with a force of at least five (5) pounds greater than the total weight of the tool.
“(c) The tool shall be so designed that it will not operate when equipped with the standard guard indexed to the center position, if the bearing surface of the guard is tilted more than 8° from contact with the work surface.”

Hilti designed, manufactured and put into use the “Hilti DX 100-L,” a powder actuated or powder assisted tool quite different, both in design and in operation, from the conventional powder actuated tools, and sought approval for its sale and use in Pennsylvania. After an informal rejection of its request, Hilti filed a petition with the Industrial Board seeking approval of its tool in spite of the fact that it admittedly failed to conform to the rules quoted above on the grounds [15]*15that the regulations, as applied to this tool, are unreasonable and should not apply, and that this tool should be exempt from compliance, or, in the alternative, requesting the board to amend its regulations to establish a separately defined category of tools into which this tool would fall, with only such regulations applicable thereto as would be reasonably required in the interest of safety, or requesting the board to promulgate a separate set of regulations for this type of tool which regulations would be reasonably necessary in the interest of safety.

Hilti points to section 4, rule 1 (c) of the rules which provides: “(c) Tools of a special design not anticipated by the regulations must be of an approved type”; and avers that the tool in question should be approved by the board under this provision.

A hearing was had before the Industrial Board and the board’s adjudication followed. Thereafter, Hilti appealed to this court.

The conventional type powder actuated tool, the type contemplated when the regulations were adopted, is a gun-type tool which looks much like a large pistol with a pistol-grip, trigger and barrel. An explosive charge similar to pistol ammunition propels through the barrel in free flight a fastener which partially penetrates the work surface (generally a wall or ceiling in building construction) against which the tool is pressed, leaving a part of the fastener protrudent to which other structural material may then be fastened. The reason for the explosive charge is that the work surface into which the fastener must go is generally too hard for the fastener to penetrate by mere blows of a hammer. The principle of this type tool, sometimes called a “stud-gun,” is that with low mass, i.e., the small lightweight fastener, the said fastener is propelled by high velocity through the barrel just as a projectile goes through a gun barrel.

[16]*16Experience with this type tool has shown that in the use thereof there is danger to the operator and others nearby from ricochet, “fishhooking,” 1 explosive spall, and drop-firing, and to persons other than the operator from overpenetration and air-firing. The regulations were designed to eliminate or reduce these hazards and as far as the conventional tool is concerned they have a reasonable relationship to the hazard and result in a much safer operation.

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28 Pa. D. & C.2d 11, 1962 Pa. Dist. & Cnty. Dec. LEXIS 122, Counsel Stack Legal Research, https://law.counselstack.com/opinion/industrial-board-v-hilti-rapid-fastening-systems-inc-pactcompldauphi-1962.