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.

May 1, 1975

Mr. Thomas F. Shannon
Collier, Shannon, Rill and Edwards
Counselors at Law
1666 K Street, N.W.
Washington, D. C. 20006

Dear Mr. Shannon:

This is in response to your letter dated April 1, 1975 and subsequent telephone conversation on the 16th, concerning the application of the standards to clicking machines, used in the footwear manufacturing industry.

The clicking machines used by members of the American Footwear Industries are not included in the class of machines designated as mechanical power presses, covered by Section 1910.217 of the standards. They are, however, subject to the safeguarding requirements of 1910.212. At present, the Office of Standards Development is in the process of incorporating ANSI Standard BI1.1-1971 to Section 1910.212, as a consensus standard with future proposed amendments.

In addition, this proposed amendment to Section 1910.217 will add more names to the list of excluded machines and the clicking machine is expected to be one of the machines listed.

Your recommendation for an official declaration is well taken and the Office of Standards Development agrees with your opinion. However, the subject of the field information memorandum will be on the scope of the ANSI standard. In the writing of the standards the scope was shortened in some cases for brevity and in no way should the entire scope as written in the ANSI standard be disregarded. It has been honored in its entirety in many cases.

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

Sincerely yours,



John K. Barto,
Chief Division of
Occupational Safety Programming