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.

April 23, 1975

Mr. Neil C. Woodworth
Hooker Chemicals and Plastics Corporation
Durez Division
North Tonawanda, N. Y. 14120

Dear Mr. Woodworth:

This is in response to your letter dated January 20, 1975, and several telephone conversations with a member of our staff, concerning whether buttons on the two-handed controls of your molding presses required a surrounding guard.

Section 1910.217(b)(6)(i) and (b)(7)(v)(a) of the General Standards require that they be "protected against unintentional operation". This protection may be in the form of the guarding as you describe, or the location or height, which would provide a natural protection.

Based on the information from the above telephone conversations and the photographs that you submitted, it has been determined that the location of these controls meet the requirements within the meaning of these standards.

Thank you for your continuing interest in safety and if I may be of further assistance, please feel free to contact me.

Sincerely,



John K. Barto,
Chief Division of
Occupational Safety Programming