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• Standard Number: 1910.217

November 19, 1980

Mr. Chris McKinnell
General Manager
Pressmation Inc.
522 Cottage Grove Road
Bloomfield, Connecticut 06002

Dear Mr. McKinnell:

This is in response to your inquiry concerning a letter from this office to the Rockford Safety Equipment Co., and confirms a conversation with a member of my staff.

Our response was specifically related to whether an electro-mechanical single stroke device fulfills the requirement for a single stroke mechanism under 29 CFR 1910.217(b)(3)(i). A copy of our response to Rockford Safety Equipment Co. is enclosed. In our response, we indicated that for such a device the intent of 29 CFR 1910.217(b)(13), control reliability, should be a primary consideration. We recognize that 1910.217(b)(13) is not directly enforceable with regard to full cycle power presses; however, employers are obligated under the general duty clause, 5(a)(1) of the Act, to provide a workplace free of recognized hazards. An electro-mechanical single stroke mechanism which effects the safety of employees who are exposed to point of operation hazards, should assure fail-safe operation and prevent the initiation of a successive stroke when a failure of the electro-mechanical device occurs. To that extent, employers are well advised to be aware of the stipulations of 29 CFR 1910.217(b)(13).

If I can be of further assistance, please call or write.

Sincerely,



John K. Barto
Chief, Division of
Occupational Safety Programming

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