OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

March 21, 1975

Mr. I. Cohn
Reliable Rubber & Plastic
Machinery Co., Inc.
2014 Union Turnpike
North Bergen, New Jersey 07047

Dear Mr. Cohn:

This is in response to your letter requesting an interpretation of the stopping limits of Mills as calculated in 1910.216(f)(2) of the Federal Register, Vol. 39, No. 125 dated June 27, 1974.

Using 100 feet per minute, as you suggested, we would calculate stopping distances as follows:

100 FPM X 1.5% = 1.5 = 18 inches stopping distance

The stopping distance is obtained by multiplying the running speed in feet by the 1.5% constant permitted for stopping. This results in a figure showing feet which must be multiplied by 12 to obtain inches for permissible stopping distance.

Please feel free to contact us if there are further questions about OSHA.

Very truly yours,

John J. Kearney
Associate Assistant Regional Director
for Technical Support/OSH