December 8, 1989
The Directorate of Technical Support is charged with the responsibility of evaluating and disseminating technical information to support safety and health professionals. Information supplied covers a wide range of subjects through a number of different delivery mechanisms including on-line services, Technical Bulletins, memoranda, manuals and Instructions. The following information is presented under the Directorate of Technical Support's Hazard Information Bulletin (HIB) Series. Bulletins are published as needed to provide relevant information regarding unrecognized or misunderstood health hazards, inadequacies of materials, devices, techniques, and engineering controls. HIB's are initiated based on the appearance of relevant information in studies and reports, through concerns expressed by safety and health professionals, employers and the public. Information is compiled based on a thorough evaluation of available facts, literature and in coordination with appropriate parties. The Directorate of Technical Support sees the HIB series as a vehicle for the dissemination of technical information to OSHA personnel. Inevitably the availability of new information will affect compliance actions. Specific guidance on compliance policy should be sought through appropriate channels.
The Boston Regional Office has brought to our attention information regarding the engineering feasibility of point of operation guarding of pre-1960 Kluge platen presses. These presses are used nationwide in the printing industry as well as in vocational education. The manufacturer, Brandtjen & Kluge, Inc., indicates that there is no practical way to bring pre-1960 Kluge presses within OSHA guarding standards.
Reference to testimony given by Mr. Henry Brandtjen, Jr., President, Brandtjen & Kluge, Inc., in a lawsuit initiated by Brandtjen & Kluge against Mr. Dale Prudhomme of the Joe Purdhomme Company, Dallas, Texas, alleging trademark infringement based on Mr. Prudhomme's repair and rebuilding of Kluge presses, has been submitted in a letter to our office by Mr. John L. Sigalos, attorney for Mr. Prudhomme:
"We would submit to you that the pre-1960 machines are safe, as Mr. Brandtjen has testified under oath, and that the issue is whether the users are indeed properly instructing their personnel how to use the machine. Use of the machine in automatic feeding mode, as sold by our client, provides adequate point-of-operation safety (OSHA Instruction STD 1-12.22). Further, our client specifically warns against hand feeding the presses in the operation and maintenance booklet supplied to its customers.
. . . Moreover, our client places prominent legends on the presses at points of operation warning against hand feeding.
. . . The letters sent out by Brandtjen & Kluge, Inc., are in our client's opinion a "false alarm," not based on fact, whose true purpose is to increase sales of new Brandtjen & Kluge presses."
The guarding of platen presses is addressed in OSHA Instruction STD 1-12.22. The directive provides guidance in applying point of operation guarding for such machines when using the face down printing method.
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