Appendix I: MECHANICAL POWER PRESS QUESTIONS AND ANSWERS

1. Scope of the Standard
   
   
2. Control Systems & Brake Monitor
   
   
3. Presence Sensing
   
   
4. Pullouts & Sweeps
   
   
5. Two Hand Trip & Controls
   
   
6. Type A & B Gates
   
   
7. Barrier Guards & Other Safeguards
   
   
8. Safety Distance
   
   
9. Record Keeping
   
   
10. Minimum Training Requirements for Power Press Operators
    
    
11. Minimum Training Requirements for Power Pressroom Supervisors

Note:

Under no circumstances will the following be used in lieu of the specific language of the law, and final determination of the requirements must be checked with OSHA. Several questions and answers are referenced according to specific sections of the law in an attempt to provide compliance assistance to interested parties.

I. SCOPE OF THE STANDARD

1. Q. Does the standard for mechanical power presses cover these presses when other materials are being worked such as nonferrous metals, plastic materials, or other materials?
   
   A. Yes
   
   
2. Q. Are press brakes covered by the standard for mechanical power presses?
   
   A. No
   
   
3. Q. If a press brake is fitted with dies and functions as a mechanical power press, is safeguarding required?
   
   A. Yes
   
   
4. Q. What type of presses or other metal working machines are exempt from Section 29 CFR 1910.217?
   
   A. Some types of presses not covered by 29 CFR 1910.217 are envelope making (window cutters, etc.) machines, dinkers and clickers used for cutting leather and other materials, brick presses, broaching machines, abrasive wheel presses, platen presses, powdered metal presses, hot bending and forming machines, forging presses.
   
   
5. Q. Are hot bending operations covered by Section 29 CFR 1910.217?
   
   A. No

II. CONTROL SYSTEM & BRAKE MONITOR

6. Q. For ungrounded circuits, is the first ground considered a failure?
   
   A. No
   
   
7. Q. When operating a successive continuous run, is a single failure in the press control system required to stop the press?
   
   A. No, it prevents a successive continuous run being initiated.
   
   
8. Q. If a press is only operated on continuous, must a single stroke mechanism be provided?
   
   A. No, however, special attention needs to be given to die changing operations. Die setters do not normally re-install barrier guards to run try-out pieces. In these cases a single stop mechanism would be required.
   
   
9. Q. If a press stroke cannot be initiated because of the brake monitor action, how is this indicated to the operator?
   
   A. The control system may have an indicator light or alarm. The visual inspection of markings on the crankshaft will show that press slide has not stopped within the safe range previously established. The press won't run.
   
   
10. Q. If the brake monitor is actuated by top stop overrun, can the brake initiation point be set earlier in the cycle if the safety distance is recalculated and two-hand controls moved?
    
    A. Yes, this practice is allowed as long as the brake is deemed to be functioning within its stopping time limit before overhaul and repairs are required.
    
    
11. Q. If a press stops at some point of the cycle due to the brake monitor, how is the press slide returned to top of stroke?
    
    A. The inch controls or other bypass circuits are used to return press slide to top of stroke.
    
    
12. Q. Must brake monitors detect brake deterioration when the brake is applied at other than top of stroke?
    
    A. No, but some types of brake monitors will give an indication of stopping time on each brake application at any point in the stroke.
    
    
13. Q. Can a press be operated on-the-hop with a brake monitor?
    
    A. No, the press slide must stop on each stroke for the brake monitor to be effective.
    
    
14. Q. Is a brake monitor necessary on a full revolution clutch press?
    
    A. A brake monitor is not required on a full revolution clutch press. Brake monitor manufacturers and users are claiming that they are feasible and useful on a full revolution clutch press.

III. PRESENCE SENSING

15. Q. Do presence sensing devices require some form of additional safeguarding to protect press operators?
    
    A. Yes, if there are areas of entry to the point of operation not protected by the sensing device, then other safeguarding is required.
    
    
16. Q. What are the limits of muting of a presence sensing device to enable parts ejection, feeding, or circuit checking?
    
    A. Muting of such devices is only permitted during the up stroke of the press slide.

IV. PULLOUTS & SWEEPS

17. Q. Are pull-outs acceptable for safeguarding the press operator when press stroke is actuated by a foot pedal or a two-hand trip not meeting the required safety distance?
    
    A. Yes, the pull-outs by themselves are recognized as an acceptable safeguard.
    
    
18. Q. Why are detailed requirements given for checking and adjusting of pull-outs?
    
    A. Pull-outs are a more personal form of safeguard whose proper functioning can be affected when operators are changed, or a new die set for operation. Visual inspection of pull-outs can detect wear of parts as well as proper action when press is stroking.
    
    
19. Q. Can a restraint be used for "hands in dies" feeding?
    
    A. No. By definition the restraint does not permit entry of the hand into the die or point of operation.
    
    
20. Q. Can a restraint used for one hand be used in conjunction with a single trip or control button for the second hand, when the second hand is used for feeding into the point of operation.
    
    A. Yes, if a safety distance is established for the one-hand trip or control button.
    
    
21. Q. What is the difference between a restraint and a pull-out device?
    
    A. A restraint prevents entry of hands or fingers to the point of operation at all times, while a pull-out device allows hand-in-dies for feeding.
    
    
22. Q. Are restraints or hold-outs a recognized form of safeguarding a point of operation hazard?
    
    A. Yes, restraints which keep operators' hands out of the point of operation at all times are an acceptable safeguard.
    
    
23. Q. Are two-hand trips recognized as an acceptable means of safeguarding the operator from the hazard of the point of operation?
    
    A. Yes, providing the safety distance between the point of operation and the two-hand trips is determined by the appropriate formula.

V. TWO HAND TRIP & CONTROLS

24. Q. What are some of the methods or means used to fix the position to two-hand trips or controls as the safety distance?
    
    A. Articulating or extendable bars or control mounts, clearly established floor position for portable control stands, or other administrative controls may be used when it is not possible to mechanically or electrically fix the portable stand or station on position.
    
    
25. Q. What methods are used to fix the position of two-hand trips or controls?
    
    A. Key-locked control stations; key-locked portable control stands; removable plug-in control stations; portable stand floor location fittings; portable stand bases which establish a safety distance; movable control bars or buttons fixed by fasteners which require the use of special tools to remove.
    
    
26. Q. Must "holding time" cover the entire period of die closing or until the hazard of die closing ceases at 1/4 inch opening?
    
    A. No, holding time can be set for any period of time during the cycle. Press stopping time is the critical factor in establishing the safety distance for safeguarding means.

VI. TYPE A & B GATES

27. Q. Is a Type A gate an acceptable safeguard with a two-hand trip or two-hand control without adequate safety distance determined by the the appropriate formula?
    
    A. Yes, the Type A gate alone will satisfy the requirements for safeguarding with any form of press actuation such as foot pedal or control, two-hand trip or control without safety distances, or others such as one-hand trip.
    
    
28. Q. Can a Type A gate be opened during the downstroke of the slide? 29 CFR 1910.217(c)(3)(ii)(a)
    
    A. No, a Type A gate remains closed.
    
    
29. Q. Can a Type B gate be opened during the downstroke of the slide? 29 CFR 1910.217(c)(3)(i)(g)
    
    A. The Type B gate, when used on a part revolution clutch press, should be designed so that it is held closed during the closing portion of the stroke. If it can be manually opened during the closing portion of the stroke, the gate must be located so that the point of operation cannot be reached prior to the slide stopping. This can be accomplished by applying the same safety distance formula used for placement of two hand controls and presence sensing devices.
    
    
30. Q. When manual feeding with hands in die, can a Type B gate or movable barrier device be used for safeguarding on a full revolution clutch press?
    
    A. Yes, a Type B gate or movable barrier device which permits manual feeding on the upstroke or when the slide has stopped on top is an acceptable safeguard.
    
    
31. Q. If a Type B gate is used as a means of safeguarding, can a presence sensing light curtain be used to actuate the Type B gate which subsequently initiates the press to work?
    
    A. Yes, the presence sensing light curtain is then only actuating the Type B gate (the operator safeguard).

VII. BARRIER GUARDS & OTHER SAFEGUARDS

32. Q. Can an interlocked barrier guard be installed on a press for protection of an operator manually feeding strip stock through openings in the side or through the movable section of the interlocked barrier guard? 29 CFR 1910.217(c)(2)(iv), (v), and (vi)
    
    A. Yes, this form of guard may be used; however, the hinged or movable section must be interlocked and can only be opened for clearing a jam or piece of scrap or die changing when the machine has stopped. In addition, all openings in barrier guards must comply with Table 0-10.
    
    
33. Q. Does the use of hand tools for feeding qualify as a "hands out of dies" operation?
    
    A. Yes
    
    
34. Q. Is compliance with paragraphs (b)(13) and (b)(14) required when hand tools are used for feeding? 29 CFR 1910.217(c)(4) and (5)
    
    A. No, because in this situation, it is a no hands in die operation.
    
    
35. Q. If presses are operated with "hands out of dies" feeding methods, must safeguarding be provided?
    
    A. Yes
    
    
36. Q. Why?
    
    A. The "hands out of dies" requirement can only be achieved when some form of operator safeguarding is utilized. Hand tool feeding, while qualifying as a "hands out of dies" procedure, along with the sliding bolster feeding method, in and of themselves, do not ensure that the operator can not get his hands in the die. These approaches should be used in with other safety devices; e.g. two-hand trip, Type A and B gates, presence sensing, etc.
    
    
37. Q. On presses operated as a "hands out of dies" for feeding must the applicable construction requirements of paragraph (b)?
    
    A. Yes, "hands out of dies operations" has no effect on employers' obligations to comply with the 29 CFR 1910.217 standards, except for the brake monitoring and control reliability requirements at 29 CFR 1910.217(c)(5), (b)(13), and (b)(14).
    
    
38. Q. Why are tools required for removal of scrap or stuck work pieces when hand feeding is allowed?
    
    A. Removal and clearing operations are not considered to be as technically difficult as the feeding of dies. The requirement will reduce the number of times that the operator's hands are in the dies and represents a compromise with the former rule for no hands in dies at all times.
    
    
39. Q. Do the requirements for testing of clutch/brake mechanism, anti-repeat feature, and single stroke mechanism apply to those presses operated in single stroke with "hands in dies" feeding only?
    
    A. 29 CFR 1910.217(e)(1)(ii) requires weekly inspections and testing of these mechanisms and features on all presses except those part revolution presses which comply with paragraphs (b)(13) and (b)(14), control reliability and brake.
    
    
40. Q. If a sliding bolster is used to feed parts, are two-hand controls required to meet the safety distance requirements?
    
    A. Yes

VIII. SAFETY DISTANCE

1. Q. Where is the safety distance measurement taken from? The die or the edge of the bolster or slide?
   
   A. The safety distance is measured from the point of operation of the die (a recognized hazard). The die dimensions may be less than or greater than the size of the slide or bolster.
   
   
2. Q. There are different formulas for calculating the safety distance on part revolution clutch machines using two hand control and full revolution clutch machines using two hand trips. What is the significance of the sub letters D_s, D_m, T_s, and T_m?
   
   A. Different sub letters are used to aid users in recognizing that two separate formulas are used for calculating safety distance depending on the type of clutch.
   
   
3. Q. When the safety distance is calculated using the formulas, what amount of supplemental distance (margin) is required to determine the point at which controls or trips must be located?
   
   A. None; however, it is expected that an additional (margin) distance will be added to allow for some brake stopping time deterioration or slide stopping point tolerance.
   
   
4. Q. What is "safety distance"? What is "separation"? Are they the same?
   
   A. "Safety distance" is a proper distance from the controls to the point of operation, as defined in ANSI B11.1-1982, -1988, and the 1994 ANSI draft proposal of April 24, 1994. "Separation" is the term used in ANSI B11.1-1982, -1988, and the April 24,1994 draft revision, which compares with the term "separation" OSHA used to refer to the distance between an operator's hand controls to require the use of both hands to operate the press.
   
   
5. Q. What is meant by separation when describing the position or arrangement to two-hand trips and two-hand controls?
   
   A. OSHA recognized the use of "separation distance" when applied to locating two-hand control buttons remote from each other to discourage attempts at one-hand actuation.
   
   
6. Q. What is the source of the 63" hand speed constant?
   
   A. European studies by Dr. O. Lobl of Sweden determined a safety distance for use in the regulation of foreign countries.
   
   
7. Q. Which formula is proper for finding the safety distance on a part revolution clutch press with two-hand controls? 29 CFR 1910.217(c)(3)(vii)(c)
   
   A. No formula for calculating safety distance on a part revolution clutch press actuated by a two-hand trip is provided. The time recommended would be that for the die closing stroke.
   
   
8. Q. Why is the position of approximately 90 degrees of crankshaft rotation chosen for determining brake stopping time?
   
   A. The longest possible stopping time should be used when calculating the safety distance. The point in the stroke near point of maximum speed or half way down was considered to be the best place to measure the longest time for stopping the slide. This conclusion is currently being challenged based on testing by several people.

IX. RECORD KEEPING

9. Q. How long must the records required by Section 29 CFR 1910.217(e) be kept?
   
   A. Section 1910.217(e) makes no provision for record retention period.
   
   
10. Q. Are Federal agencies required to report injuries to press operators?
    
    A. No.
    
    
11. Q. Must a written record be kept of pull-out adjustment and testing for each shift change, operator change, or new die set-up? 29 CFR 1910.217(c)(3)(iv)(d)
    
    A. Yes. The record keeping requirements of 29 CFR 1910.217(e) are applicable.
    
    
12. Q. If an employee is injured by a broken piece/part thrown from the die, must a report be sent to the OSHA Directorate of Safety Standards?
    
    A. No, only injuries to employees which occur within the point of operation are required to be reported.
    
    
13. Q. Where did the weekly period for inspections come from?
    
    A. ANSI B11.1 - 1971 explanatory column accompanying requirements for inspections.
    
    
14. Q. What periods are recommended by the ANSI B11.1 - 1997 for press inspections?
    
    A. B11.1 - 1971 recommends weekly, monthly, or possibly longer periods for press and safeguarding inspections, testing, and maintenance.
    
    
15. Q. Are records required to be kept?
    
    A. Yes, B11.1 requires records of inspections.
    
    
16. Q. For how long?
    
    A. No definite retention periods are prescribed by OSHA or ANSI for power press records.
    
    
17. Q. Are periodic inspections and records required for all presses even when operated on continuous or with no hands or dies?
    
    A. Yes, every press is required to be inspected and maintained to protect the safety of operators, die setters, and others.
    
    
18. Q. Is is necessary to report minor injuries such as a scratch or pinched finger when feeding a die?
    
    A. No, only report those injuries which qualify for listing on the OSHA Form 200.

X. MINIMUM REQUIREMENTS FOR POWER PRESS OPERATORS TRAINING

The operators of mechanical power presses must be trained in all phases of the operation of the equipment and its capabilities and limitations, and;

1. All press controls and how to use them;
   
2. The safety guards and devices incorporated on the machines and the correct use of each;
   
3. The use of tools for removing stuck work and the use of swabs, brushes, or oil cans for lubricating dies and stock;
   
4. Understanding why, when, and how to use personal protective equipment, such as safety glasses, gloves, safety shoes, and hearing protections;
   
5. The storage of parts, tools, or other objects on dies, die sets, bolster plates, or press components not designed to retain them; present hazards of falling on operators; and possible pinch points with moving components. Operators must be aware of these hazards, as well as the basic housekeeping around the press areas;
   
6. Not to operate the press until the press has been checked and tested several times prior to production operations. He/she should report any problems which he/she observes to the proper person; and
   
7. Employees who are going to operate presses should receive a minimum of 8 hours on-the-job training under supervision prior to being assigned to operate the press. This could be up to 2 weeks or more, depending on the complexities of the operation.

XI. MINIMUM TRAINING REQUIREMENTS FOR PRESSROOM SUPERVISORS

1. The foreperson must be informed of his/her accountability to the employer and the employees who work with him/her.
   
2. He/she must know the hazards of power press operations and their set-up and maintenance.
   
3. The pressroom foreperson must be knowledgeable about the intended function of the safety guards and devices, and the correct adjustments and uses of each.
   
4. He/she must check each set-up and be sure that all operators are instructed in safe power press operations before they start work.
   
5. It is his/her responsibility to ensure that correct operating procedures are being followed.
   
6. The foreperson must see that all maintenance is performed and that presses are in safe repair prior to their operation. As the employer's representative, the pressroom supervisor is responsible for the training and operations of the employees under his/her control.