Powder-Actuated Tool Card - Washington (DOSH)

Under federal rules, the operator of a powder-actuated tool must be trained on the particular tool. Washington asks for proof, and it asks for it in the operator's pocket. In Washington, the training must come from an instructor authorized by the tool manufacturer, the operator must pass the manufacturer's written exam, and the operator must carry a qualified operator's card signed by both the instructor and the operator whenever they use the tool. This Washington Powder-Actuated Tool Card Toolbox Talk covers the card, the instructor, and the Washington operating rules that go with them.

Where the boundary of this talk sits#

This talk covers Washington's qualification, card, and operating rules for powder-actuated fastening tools. How the tools work, velocity classes in depth, and ricochet and pass-through hazards belong to the general powder-actuated tool talk.

The anchor#

Here is the distinction that carries this whole talk: in Washington "trained on the tool" means a specific chain of paper — an instructor trained and authorized by the tool manufacturer, who holds a valid instructor's card; an operator who has shown the instructor they can use the tool, then passed a written exam provided by the manufacturer; and a wallet-size qualified operator's card, signed by both, that the operator must carry while using the tool and that can be revoked immediately for breaking the safety rules — so a worker who was shown how to use the tool by a coworker, however experienced, is not a qualified operator in Washington.

The authorized instructor#

WAC 296-155-36319 says only persons trained and authorized by the tool manufacturer, or by an authorized representative of the manufacturer, are qualified to be instructors. The manufacturer must keep a list of all instructors it has authorized to instruct and qualify operators. Each instructor must have in their possession a valid authorized instructor's card, about 2½ by 3½ inches (6 x 9 cm), issued and signed by an authorized representative.

Instructors must be able to disassemble, service, and reassemble the tool, recognize worn or damaged parts or defective operation, and train and test operators before issuing a qualified operator's card. The instructor's card may be revoked by the authorizing agent or by the Department of Labor and Industries. If a new hire says they were qualified somewhere else, it is fair to ask who the instructor was.

The qualified operator#

WAC 296-155-36321(1) says the operator must be trained by an authorized instructor and must be capable of:

• reading and understanding the manufacturer's instruction manual;
• cleaning the tool correctly;
• recognizing any worn or damaged parts or defective operation;
• recognizing the number-color code system the standard uses to identify power load levels; and
• using the tool correctly within the limitations of its use, and demonstrating competence by operating it in the presence of the instructor.

Under (2), after training, the operator must complete a written examination provided by the manufacturer, covering the requirements of the standard, the powder-actuated fastening system, and the operation and maintenance of the specific tool.

The card#

Under WAC 296-155-36321(3), each applicant who meets the requirements receives a qualified operator's card, issued and signed by both the instructor and the applicant, wallet size, about 2½ by 3½ inches (6 x 9 cm). While using the tool, the operator must carry the card.

The card carries its own warning: failure to comply with any of the rules and regulations for safe operation of powder-actuated fastening tools must be cause for the immediate revocation of the card.

The qualified operator section itself sets no expiration date for the card. What it does set is a condition: the card lasts only as long as the operator keeps following the rules. An operator who points a tool, skips the daily check, or fires into material they never tested is giving cause for immediate revocation.

Operating rules#

WAC 296-155-36313 sets the operating rules. Among them:

• only qualified operators may operate tools;
• use the lowest velocity class of tool that will properly set the fastener, and operate in strict accordance with the manufacturer's instructions;
• operators, assistants, and adjacent personnel must wear eye or face protection, or both, when the tool is in use, and hearing protection when making fastenings in confined areas;
• each day, before use, the operator must inspect the tool using the manufacturer's recommended testing methods, and any tool not in proper working condition must be removed from service immediately and tagged "defective";
• use the shield, fixture, adapter, or accessory the manufacturer recommends for the application, and only the fasteners and power loads the manufacturer recommends, or ones giving the same level of safety and performance;
• before fastening into questionable material, use a fastener as a center punch to check its suitability;
• do not load a tool unless it is being prepared for immediate use, and unload it at once if work is interrupted;
• never point a loaded or empty tool at anyone, and keep hands clear of the open barrel end;
• hold the tool perpendicular to the work surface unless the manufacturer recommends otherwise for a specific application;
• after a misfire, hold the tool firmly against the work surface for 30 seconds, then follow the manufacturer's instructions; and
• keep power loads of different levels and types in separate compartments or containers.

The sign and the storage#

WAC 296-155-36313 also requires a sign at least 8 by 10 inches (20 x 25 cm), with boldface letters at least 1 inch (2.5 cm) high, posted in plain sight on all construction projects where the tools are used, with wording similar to "powder actuated tool in use."

WAC 296-155-36317 requires the tool to be serviced and inspected for worn or damaged parts at the intervals the manufacturer recommends, and tools and power loads to be locked in a container and stored in a safe place when not in use.

Washington versus federal#

The federal rule, 29 CFR 1926.302(e)(1), says only employees trained in the operation of the particular tool in use may operate a powder-actuated tool, and (e)(2) requires the tool to be tested each day before loading. It does not require a manufacturer-authorized instructor, a manufacturer's written exam, an operator card, or a job-site sign. Washington requires all four.

Where the duty sits#

WAC 296-155-36319 sets the authorized instructor and instructor card. WAC 296-155-36321 sets operator training, the manufacturer's exam, and the operator card carried while using the tool. WAC 296-155-36313 sets the operating rules and the job-site sign. WAC 296-155-36317 sets maintenance and locked storage. For contrast, federal 29 CFR 1926.302(e).

What can go wrong?#

• A laborer borrows the tool because "he's watched it done a hundred times."
• The operator's card is in the truck, not in their pocket.
• A tool that failed its daily check goes back in the box untagged.
• A misfired tool is lifted off the work right away.
• Loads of different power levels are mixed in one pouch.

How do we manage this properly?#

• Card in your pocket — signed by you and a manufacturer-authorized instructor.
• Check the tool every day — tag it "defective" if it fails.
• Eye and face protection — for the operator, the helper, and anyone nearby.
• Load only to fire — unload if you stop.
• Misfire? Hold 30 seconds — then follow the manufacturer.
• Post the sign, lock up the tool and loads.

Before you start#

Show your operator's card. Inspect the tool, check the load color against the job, and center-punch any material you're not sure of.

Talk it over#

• Who on this crew holds a powder-actuated tool card, and who trained them?
• What do we do if the tool doesn't fire?
• Where is the "powder actuated tool in use" sign posted?

The bottom line#

In Washington, only qualified operators may use powder-actuated tools. That means training from an instructor authorized by the manufacturer, a passed manufacturer's written exam, and a signed wallet card carried while using the tool, which can be revoked for breaking the safety rules. Operators inspect the tool daily, load only for immediate use, never point it at anyone, hold it 30 seconds after a misfire, and work under a posted "powder actuated tool in use" sign.

Frequently asked questions about Washington powder-actuated tool rules#

Do you need a card to use a powder-actuated tool in Washington?

Yes. Under WAC 296-155-36321, the operator must be trained by an instructor authorized by the tool manufacturer, pass a written exam provided by the manufacturer, and receive a qualified operator's card signed by both the instructor and the operator. The operator must carry the card while using the tool.

Download the Washington powder-actuated tool card toolbox talk PDF#

Download this Washington Powder-Actuated Tool Card Toolbox Talk as a printable PDF in English and Spanish, and check every operator's card before the tools come out.

Related toolbox talks#

• Powder-Actuated Tools Safety
• Nail Gun Safety
• Eye and Face Protection
• Hand and Power Tool Safety

Sources#

• Washington State Legislature, WAC 296-155-363 — Safety requirements for powder actuated fastening systems (in accordance with ANSI A10.3-1985): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-363
• Washington State Legislature, WAC 296-155-36313 — Operation (qualified operators only; lowest velocity class; eye or face protection; daily inspection and "defective" tag; center punch test; load only for immediate use; do not point; perpendicular; misfire 30 seconds; separate power loads; sign at least 8 x 10 in with 1-in boldface "powder actuated tool in use"): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-36313
• Washington State Legislature, WAC 296-155-36317 — Maintenance and storage (service at manufacturer's intervals; tools and loads locked in a container): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-36317
• Washington State Legislature, WAC 296-155-36319 — Authorized instructor (trained and authorized by the manufacturer; manufacturer's list; instructor card; revocation): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-36319
• Washington State Legislature, WAC 296-155-36321 — Qualified operator ((1) training and demonstration; (2) manufacturer's written exam; (3) card signed by instructor and operator, carried while using the tool, revocation; WSR 16-09-085, effective 5/20/16): https://app.leg.wa.gov/wac/default.aspx?cite=296-155-36321
• OSHA, 29 CFR 1926.302(e)(1)–(2) (trained on the particular tool; tested each day before loading): https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.302

Written by FieldSafetyTalk's safety professional — a CSP, ASP, CHST and OSHA Authorized Outreach Trainer with 14+ years of international construction safety experience across federal, heavy civil, and industrial projects.

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