Interpretation ID: aiam3333
Project Manager
Amerace Brands Division
Amerace Corporation
1201 Mark Street
Elk Grove Village
Illinios(sic) 60007;
Dear Mr. Uding: This responds to your July 15, 1980, letter asking whether Standard No 125, *Warning Devices*, permits the manufacture of a device that must be assembled by the user prior to use. The device that you describe would require its base to be attached to a triangular section by the use of a threaded stud and a wing nut.; Standard No. 125 states in section S5.1.3 that '[t]he warning devic shall be designed to be erected, and replaced in its container, without the use if tools.' This statement implies that some manual operation to erect a warning device is permissible as long as the assembly does not require the use of any tools. For the device that you mention, it would appear that its two section would be coupled together by the use of a wing nut which would be tightened manually without the use of tools. If this description of your device is accurate, it is permissible to produce a warning device in this manner.; Sincerely, Frank Berndt, Chief Counsel