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

Robert L. Hinman, ASSE
Managing Consultant
Employers Safety Consultant Services
5939 Cullen
Lincoln, Nebraska 68506

Dear Mr. Hinman:

This is in response to your letter of May 21, 1975, concerning interpretation of 29 CFR 1910.217, Mechanical Power Presses, published December 3, 1974.

This standard revokes that "no-hands-in-dies" requirement and at the same time, sets forth safety regulations to protect employees from point of operation injuries.

To answer your question concerning a power press having two-hand controls or trips that are too close to the point of operation: If two-hand controls or trips are used by themselves, they must meet the safe distance formula requirements as set forth in 29 CFR 1910.217(c)(3)(vii)(c) and (viii)(c), respectively. If either pull-outs or a "Type A" gate-sensing device is used in conjunction with the two-hand devices, then the pull-out or gate becomes the primary protection. Pull-outs, Type A gates and Type B gates do not require application of the safe distance requirements.

The fail safe is required on part revolution clutches in conjunction with the operator feeding or removing parts by placing one or both hands in the point of operation and using a two-hand control, Type B gate or movable barrier sensing device for safeguarding. In addition, a brake monitor must be used with compliance required by November 11, 1975. These controls and monitor systems must comply with 29 CFR 1910.217(b)(13) and (14) of these regulations.

Two-hand control systems must be designed to deactivate and stop the slide if pressure is removed from one of the control buttons.

Two-hand trips activate that slide when depressed simultaneously and when released do not stop the slide but allow it to complete the cycle. The safe distance requirements in 29 CFR 1910.217(c)(3)(vii)(c) are critical when this is the only system used for safeguarding.

Hopefully, this information and the enclosed brochure will be helpful to you in clarification of these standards. If I may be of any further assistance, please feel free to contact me.

Sincerely,



Janet H. Sprickman,
Acting Chief
Division of Occupational Safety Programming