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April 15, 1991
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
THRU: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
SUBJECT: Clarification of Scope of OSHA Instruction STD 1-12.22
It has come to our attention that the scope of the action section of OSHA
Instruction STD 1-12.22 needs clarification in order to assure uniform
application in the field. The subject of the instruction is 29 CFR
1910.212(a)(3)(ii) Point of Operation Guarding for All Machines; As Applied
to Hand-Fed Engraving Presses Used in the Engraved Stationary Manufacturing
Industry.
Paragraph 4. Action in OSHA Instruction STD 1-12.22 applies only to hand-fed
engraving presses used to apply ink to the underside of paper. It does not
apply under any other conditions. For example, it does not apply when
engraving takes place without the use of ink. For another example, it does
not apply when materials other than stationery are being engraved. It also
does not apply when engraving is not being performed.
For situations involving engraving presses where Paragraph 4. Action of OSHA
Instruction STD 1-12.22 does not apply, the full scope of 29 CFR 1910.212 is
applicable.
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