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.

July 17, 1975

Mr. Russell F. Shea
Safety-Security Manager
Rubbermaid, Inc.
Wooster, Ohio 44691

Dear Mr. Shea:

This is in response to your letter of May 13, 1975, addressed to the Chicago Regional Office of the Occupational Safety and Health Administration (OSHA), and a telephone conversation with a member of my staff concerning the applicability of the standards to your mechanical goods presses.

Based on the information contained in the brochure and blueprint forwarded to this office, it has been determined that the above equipment does not meet the requirements of the operational definition as set forth in ANSI B11.1-1971 for mechanical power presses. Therefore, Section 1910.217 does not apply to this type of equipment but is governed by Section 1910.212.

The screen guard and micro-switch device installed on the McNeil Press is an acceptable method as point of operation guarding, however, the screen guard does not completely enclose the front and sides of the platens, thereby allowing openings where the hands could be inserted.

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

Sincerely,



Janet H. Sprickman
Acting Director
Division of Occupational Safety Programming