Hope there are more posts to the site. It is easy to do. I can tell you a ll that someone listens to these sometimes, but if you don't voice your opi nion, it will be assumed that the issue is of no importance to you. I woul d like to have had a bit of time to edit this, but I saw that the surroundi ng issues around this proposed regulation had already been closed to commen ts. I wanted to get on it and get it out before I forgot or was too busy.
Here's what I posted:
I have been in the construction trades for 40 years off and on. I have bee n an owner operator of a small carpentry and woodworking business for about 35 of those years. In my experience there is a great deal of similarity i n the observance of safety issues between the home shop worker as well as t he professional. In short, the similarity is that both casual user and pro fessional need training and education, not additional safety appliances or devices added to tools. Some of the appartus required over the years have a valid place in both the home shop as well as in a professional setting, b ut others are removed, ignored or not maintained at an operational level.
I truly believe based on my own personal experience of instructing and over seeing employees and job sites that the saw brake devices will be disabled or wired around to make the saws work without them. Anything that would st op work that would be attributed to the saw brake would cause it to be disa bled in some fashion. Doubtful that it would be reset and rearmed for prop er function after a job stoppage. Also, the loss of a blade that could cos t as much as $300 from the mechanism firing would certainly make any small business man think about rearming the saw brake device. Besides the down t ime on the job, a firing of the device will require that a qualified techni cian of some sort reinstall the replacement firing mechanism of the brake. Additionally, there will be a need to purchase and have on hand another fi ring device, adding not only to the expense of the saw brake device, but pu tting the contractor at risk of not being able to locate a replacement whic h would cause more job site down time. NO doubt that occasion would cause the contractor to "wire around" the problem. IF the device ever fired off by accident or by a bad reading, a contractor will be looking at the purch ase of a new blade, a new brake stop firing device as well as all the down time for (possibly) several employees while the machine is reequipped and r eset. If there is ever a false positive, then certainly a contractor will work hard to permanently disable the saw blade brake. I strongly believe t his additional device that adds to the cost of a saw will be seen by most p rofessionals as not only unnecessary, but as an irritant to be disabled at the first opportunity.
My experience with homeowners/non professionals and their saws is different . Almost all home accidents come from an occurrence known as "kickback". This happens when a saw is used incorrectly. The wood being cut is put in a position that binds the blade against the guiding device (a "fence" or "m iter gauge") or the wood is no longer fed in a straight line into the blade causing the saw to aggressively grab the wood rather than cut it. This gr ab will cause the wood to be removed from the operator's grasp and will oft en "kickback" the wood towards or into the operator or off the table of the saw. The saw makers and the government have provided different devices to help mitigate this problem, but I very rarely go into a home shop where th e recommended table saw safety devices are being used, or used properly. Kickback is a technique issue and rarely happens with proper use of the tab le saw. it is important to note that a saw braking mechanism will NOT prev ent or mitigate the occurrence kickback in any way.
I rarely see hands or digits cut by table saws in a home or professional en vironment. Very rarely. Most people that use them have a healthy respect for the tool due to its size and power, and using the tool give ther operat or a tremendous sense of its power. Almost all operators have a very healt hy respect for this tool and use it carefully. I truly believe that if the re was an effective blade braking device attached to a table saw then most operators would become overconfident and lazy, knowing that if they have a lapse of judgement of concentration, they wouldn't suffer any risk of injur y. In the particular case of the table saw, a very healthy fear of the mac hine is a great thing and does more to prevent injury than any attached dev ice.
In closing, I hope you can see that while some safety devices are good idea s, the idea of a saw blade brake is not. Not for the hobbyist or the profe ssional. Although for two very different reasons, neither would benefit f rom it. This is an issue that has been around for years now, and while the saw blade brake technology certainly has its place, most are overwhelmingl y against it, and mandating it would be of little or no value to table saw users.
Thank you for your time and attention.