OSHA Instruction STD 1-12.23A July 12, 1994 Office of General Industry
Subject: Guarding of Three-Roller Printing Ink Mills
A. Purpose. The purpose of this instruction is to clarify the
guarding requirements of the subject standard relative to the ingoing nip
point on three-roller printing ink mills and to assure uniformity in the
enforcement of the standard nationally.
B. Scope. This instruction applies OSHA-wide.
C. Reference. 29 CFR 1910.212(a)(1)
D. Cancellation. OSHA Instruction STD 1-12.23, January 2, 1979, is
E. Action. The following requirements meet the intent of 29 CFR
1910.212(a)(1) for protecting the operators of three- roller printing ink
(1) All three-roller printing ink mills shall be equipped with a
sufficient number of safety controls and emergency stops such as
pressure-sensitive body bar, safety trip rod, safety trip cable or wire cord
at each work station. The number of safety controls and emergency stops and
the location will depend on the mill size (length of the rollers) and on the
operator's exposure to the ingoing nip point at each work station.
(2) All mills that require the operator to use knives or spatulas
to hand-feed the ink onto the feed roller or to throw-back mill ends (spread
the ink on the feed roller) shall have knives or spatulas at least 18 inches
(3) All mills that are fed from the apron side with tub tilters and
require a platform shall be provided with a bar in front of the feed roller
or an expanded metal guard in front of the work platform.
(4) Each mill shall be provided with one of the following nip point
guards or equivalent which shall be used during the mill wash-up
(i) A trapezoid shaped guard or hardwood, nylon, or
teflon which is one inch longer than the roller surface
(ii) A V-shaped metal guard equipped with vertical
hangers that allows suspension from overhead or from the side of the Bill and
is one inch longer than the roller surface length.
(iii) A metal folding flat-plate guard that extends
across the entire nip point area of the rollers. The guard shall ride on the
rollers in such a manner that it prevents access to the nip point
(1) It has been brought to the attention of the National Office
that citations have been issued for lack of nip point guards on three-roller
printing ink mills. The National Association of Printing Ink Manufacturers,
Inc. contends that it is not feasible to operate the three-roller printing
ink mills with a nip point guard due to the required operating procedures to
obtain a homogenous ink.
(2) There is an American National Consensus Standard, ANSI
B177.1-1975, Safety Requirements for Three Roller Printing Ink Mills and a
final supplement (dated January 9, 1979) which clarifies that a nip point
guard is required on the mill only during the wash-up operation. ANSI has
proposed to revise ANSI B77.1-1975 tentatively in 1994. The proposed
standard may incorporate the 1979 supplement as part of the standard. During
the wash-up operation the pressure on the rollers is released just enough for
loose contact. With the mill running at its lowest speed, the operator holds
the cleaning and drying cloth against the roller. A nip point guard prevents
the cloth from getting in between the rollers and possibly drawing in the
operator's fingers or hand.
G. Federal Program Chance. 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, CH-2.
2. Explain the technical content of the change to the State
designee as requested.
3. Ensure that State designees are asked to acknowledge receipt of
the Federal program change in writing to the Regional Administrator as soon
as the State's intention is known, but no later than 70 calendar days after
the date of issuance (10 days for mailing and 60 days for
4. This acknowledgement should include a description either of the
State's plan to follow the guidelines in this Instruction or of the reasons
why the change should not apply to that State.
5. Advise the State designees that a plan supplement is not
required for implementation of this change. However, if the State's
interpretation of its standard is different from OSHA's, the State shall
submit a copy of its interpretation to the Regional Administrator.
John B. Miles, Jr., Director Directorate of Compliance Programs
DISTRIBUTION: National, Regional and Area Offices All Compliance Officers
State Designees 7(c)(1) Project Managers NIOSH Regional Program Directors