OSHA Instruction CPL 2-1.25 February 14, 1997 Directorate of Compliance
Subject: Guidelines for Point of Operation Guarding of Power Press Brakes
A. Purpose and Summary. This instruction provides guidelines for
compliance officers who determine compliance with the guarding requirements
for power press brakes. When guarding by barriers or physical devices is
infeasible, guarding by "safe distance" is permitted if the employer meets
conditions outlined below.
B. Scope. This instruction applies OSHA-wide.
C. Action. Regional Administrators and Area Director shall ensure
that CSHOs performing inspections at workplaces where power press brakes are
used are aware of these guidelines and that they follow them when
D. Discussion. OSHA's machinery and machine guarding regulations
(29 CFR 1910 Subpart O) require one or more guarding methods to protect
(operating, minor servicing and other nearby) employees from exposure to
hazardous machine energy. These methods include guarding by physical
barrier(s), by physical device(s), and by maintaining safe distance(s).
1. To protect employees who are not operating or performing minor
servicing from exposure to hazardous machine energy, an employer must provide
power press brake guarding by physical barrier(s) or by restricting access to
power press brakes.
2. A power press brake must not be "energized" (as defined under
paragraph 1910.147(b)) when the point of operation is not guarded by one or
more physical barriers or physical devices unless: (1) under the operating
control of a trained operator (see paragraph F), (2) the operating control of
an employee authorized to perform minor servicing which complies with the
note following paragraph 1910.147(a)(2)(ii)(B), or as provided under the
servicing and maintenance testing and positioning requirements of paragraph
3. Employees performing minor servicing on machine(s) or equipment
during normal production operations must be protected from exposure to
hazardous energy by physical barrier guards and when such guarding is not
feasible, by alternative measures which otherwise provide effective
protection. When machine(s) or equipment are not in normal production
operations, servicing and maintenance must be performed under the control
(lockout/tagout) of hazardous energy requirements of paragraph 1910.147 or
4. During normal production operations, the power press brake
operator(s) must be protected to the extent feasible by physical barrier(s)
or physical device(s) from exposure to hazardous energy sources not at the
point of operation and elsewhere on the power press brake.
5. Because of constraints imposed by certain manufacturing or
fabricating processes, safeguarding by maintaining a safe distance from the
point of operation may be acceptable but only when safeguarding by
physical barrier or physical devices is not feasible. "Safe distance"
means the clearance between an employee (typically his or her fingers holding
and supporting a piece part) and the power press brake point of
6. Safeguarding by maintaining a "safe distance" is acceptable
a. The employer demonstrates that physical barriers and
physical devices are not feasible to guard the power press brake point of
operation. Physical devices typically include: two hand controls, holdouts
or restraints and presence sensors.
b. The employer demonstrates that power press brake point of
operation guarding by maintaining a safe distance is limited to one-time
only fabrication of made-to-order or custom-made piece parts. Small quantity
runs, typically performed in job shop or model shop establishments may be
affected by this provision; high volume piece part rates of production will
not. A "small quantity run" means fabrication of more than one of the same
piece parts over a continuous timeframe of no more than four hours per
NOTE: Special feasibility guidelines for small quantity
runs: When physical guards and physical devices are not feasible for
small quantity runs as defined above, safeguarding by maintaining a safe
distance as described in this directive is an alternative to power press
brake replacement or major renovation which otherwise could provide employee
c. The employer has a safety program which includes safe work
procedures, training, and supervision to ensure that work is performed using
"safe distance" alternative measures.
d. The employer has a workplace history of operating power
press brakes safely by maintaining a safe distance from the point of
operation. Such a history is characterized by absence of injuries related to
failure to maintain a safe distance. Workplace history will be evaluated by
Compliance Safety and Health Officer review of employer records and
interviews or observations of employees.
7. Safeguarding of power press brakes is covered by American
National Standards Institute standard ANSI B11.3-1982. OSHA recognizes this
ANSI standard as the national consensus standard covering power press brakes
guarding. Paragraph 188.8.131.52 or the ANSI B11.3-1982 standard specifically
addresses safeguarding by maintaining employee(s) at a safe distance when a
power press brake is being operated. By specific notation in paragraph
184.108.40.206, "[a] dimension value has not been assigned to the minimum safe
distance." For the purpose of maintaining a "safe distance" as discussed in
this instruction, the operating employee and helping employee(s) must not
approach closer than necessary and in no case, closer than 4 inches (10.16
centimeters) to the power press brake point of operation. The minimum safe
distance of 4 inches (10.6 cm) shall be measured from the exterior point of
contact of the power press brake die closest to an employee.
E. "Safe Distance" Safeguarding Program. An employer who adopts
"safe distance" protection must have (and be prepared to demonstrate to OSHA)
an effective program. An employer can meet this obligation by establishing
and having employees follow an effective program which includes exposure
prevention procedures and training and enforcement of these procedures as
delineated in paragraphs F through J below.
F. Exposure Prevention Procedures. A "safe distance" exposure
prevention procedure must be developed and documented by the employer and
utilized by employee(s). The exposure prevention procedure must include
provisions for maintaining a minimum safe distance as discussed in paragraph
G. Training. Employees must be trained to follow the
aforementioned exposure prevention procedure(s) before operating a power
press brake covered under the procedures.
1. Training Content. Employee training must include at
least the following:
a. The need for a safety oriented working relationship between
the power press brake operator and when required, his or her
b. The function and purpose of operating controls: operating
mode controls; die space height adjustment positions: and other brake
c. The hazards of placing any parts of the body within the
point of operation.
d. The hazards and potential exposure related to each specific
piece part bending operation particularly with respect to the piece part
itself (for example, whipping) and to tooling (including loading and
e. The function and purpose of hand-feeding tools.
f. The dangers of unsafe work practices, inattention,
horseplay, and misuse of equipment.
g. The necessity and importance of reporting immediately to
the supervisor any condition concerning the power press brake and its
operation that may affect the safety of an employee.
2. Effectiveness of Training. The employer must ensure
that after training, employees perform applicable exposure prevention
procedures proficiently. Power press brake operators and helpers must also
comply with the safe operating instructions and recommendations of the power
press brake manufacturer or industry-recognized safe working practices for
power press brakes. [Successful completion of apprenticeship training may be
referenced to demonstrate this latter element of employee
H. Retraining. Retraining must be conducted whenever a periodic
inspection (see paragraph J below) reveals, or whenever the employer has
reason to believe, that there are deviations from or inadequacies in an
employee's knowledge or use of exposure prevention procedure(s) or other work
practices required to operate a power press brake safely. This restraining
must introduce new or revised control methods and procedures, as necessary,
and must reestablish employee proficiency to operate the poser press brake
I. Supervision. The employer must ensure, through effective
supervision, that power press brakes are operated only by trained employees
and must enforce the work practices on which power press brake operator
training is based. This supervision must include periodic inspections as
delineated in paragraph J below. Any deviations or inadequacies in the
exposure prevention procedures or work practices must be corrected promptly.
Employer measures must include retraining and other appropriate corrective
J. Periodic Inspection. An employer must conduct a periodic
inspection of the "safe distance" exposure prevention procedure at least
annually to ensure that this procedure and other provisions in this
instruction are being followed. This periodic inspection must be performed
by a trained person, that is, an inspector, other than the person(s) using
the "safe distance" exposure prevention procedure. The periodic inspection
must be designed to identify any deviations or inadequacies. The periodic
inspection must include a joint review by an inspector and each trained
employee of that employee's responsibility under the exposure prevention
procedure. The employer must ensure that the periodic inspections have been
performed. Normally, the employer must be able to identify the power press
brake on which the exposure prevention procedure was being utilized, the date
of the inspection, the employee(s) included in the inspection, and the person
performing the inspection.
K. Enforcement. Whether or not safeguarding is provided by
maintaining a safe distance, an employer shall be cited for violation of
paragraph 1910.212(a)(3)(ii) when a physical barrier or a physical device is
feasible (except as otherwise allowed under paragraph D.6.b above) but not
used to protect employees from the point of operation of a power press brake.
When physical guards and physical devices are not feasible and safeguarding
by maintaining a safe distance is not provided as discussed in paragraph D.7.
of this instruction, an employer shall be cited for violation of Section
5(a)(1), "The General Duty Clause," of the Occupational Safety and Health
L. Contact for further information. Questions regarding this
instruction shall be directed to the Directorate of Compliance Programs and
to the attention of Mr. Ronald J. Davies, (202) 219-8031, extension 110, in
the Office of Safety Compliance Assistance.
M. Power Press Brake Injuries. Compliance Safety and Health
Officers who discover instances in which power press brake-related injuries
have occurred, are requested to find out the circumstances of the incident
and report briefly to the Office of Safety Compliance Assistance, attention
Mr. Ronald J. Davies. Please provide (to the extent feasible) the following
incident information: the name and type of establishment, address and type
of accident site, date of the incident, type of work being performed, make
and model of the power press brake and a description of the safeguarding
being used in the workplace at the time of the incident.
1. OSHA Instruction STD 1-12.12, October 30, 1978, 29 CFR
1910.212, General Requirements For All Machines, As Applied to Power Press
2. OSHA Memorandum, March 25, 1983, Point of Operation Guarding on
Job Shop Operations Utilizing Power Press Brakes.
3. American National Standards Institute Standard ANSI B11.3-1982,
Safety Requirements for Construction, Care, and Use of Power Press
4. 29 CFR 1910.212, General Requirements for Machine
O. Cancellations. This instruction cancels OSHA Instruction STD
1-12.12: 29 CFR 1910.212, General Requirements For All Machines, As Applied
to Power Press Brakes. Also, OSHA's March 25, 1983, memorandum on "Point of
Operation Guarding on Job Shop Operations Utilizing Power Press Brakes" is
rescinded effective the date of this instruction.
P. Federal Program Change. This instruction describes a Federal
program change which affects State Programs. Each Regional Administrator
1. Ensure that this change is promptly forwarded to each State
designee using a format consistent with the Plan Change Two-way Memorandum in
Appendix P, OSHA Instruction STP 2.22A, State Plans Policies and Procedures
2. Explain to each State designee upon request the content of the
change and the guidelines detailed in this instruction and provide technical
assistance as necessary.
3. Ensure that the State designees acknowledge receipt of this
Federal program change in writing to the Regional Administrator when the
State's intention is known, but not later than 70 calendar days after
issuance (10 days of mailing and 60 days for response). This acknowledgement
must include a statement indicating whether the State will follow the
guidelines in this instruction or develop alternative guidelines.
4. Ensure that State designees submit a plan supplement in
accordance with OSHA Instruction STP 2.22A, CH-3, as appropriate, following
the established schedule that is agreed upon by the State and Regional
Administrator to submit non-Field Operations Manual/OSHA Technical Manual
Federal program changes.
a. The State plan supplement should be in the form of a State
directive or policy/procedure document, which details procedures for
implementing the safety guidelines in the State.
b. The State's acknowlegement of the Plan Change Two-way
Memorandum may fulfill the plan supplement requirement if the appropriate
documentation is provided.
5. The RA shall review policies, instructions, and guidelines
issued by the State to determine that this change has been communicated to
Greg Watchman Acting Assistant Secretary
Distribution: National, Regional, and Area Office All Compliance Officers
State Designees NIOSH Regional Program Directors Consultation Project