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• Standard Number: 1910.217

April 29, 1982 

MEMORANDUM FOR:     CURTIS A. FOSTER
                   REGIONAL ADMINISTRATOR

THRU:               JOHN MILES, DIRECTOR
                   FIELD COORDINATION

FROM:               PATRICK R. TYSON
                   DIRECTOR, FEDERAL COMPLIANCE
                     AND STATE PROGRAMS

SUBJECT:  An Interpretation of 29 CFR 1910.217(b)(3)(i) as requested
Although 29 CFR 1910.217(b)(3)(i) requires the installation of a single stroke mechanism on full revolution mechanical power presses, the absence of the device may be classified as a de minimis violation if all the following circumstances prevail:

1. The point of operation is completely enclosed with an effective fixed barrier guard, and is in full compliance with 1910.217(c)(2)(i)(b).

2. Process material is automatically or mechanically fed into the point of operation (Mechanical feeds could utilize semi-automatic fixturing).

3. There is no actual or potential employee exposure to the point of operation, per FOM Chapter VIII paragraph 3.

4. Die setters are safeguarded in conformance with OSHA Instruction STD 1-12.24, primarily paragraphs E.3 and E.4.

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