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 29, 1975

Mr. Sanford Evenchik
Safety Coordinator
Lester Industries, Inc.
25661 Cannon Road
P. O. Box 46309
Bedford, Ohio 44146

Dear Mr. Evenchik:

This is in response to your letter of May 14, 1975, which was forwarded to this office for reply through our Chicago Regional Office. The questions concerned punch presses and the revised standard, 29 CFR 1910.217, Mechanical Power Presses, dated December 3, 1974. For clarity your questions are answered in the same sequence as asked in your letter of inquiry.

1. "Capable of supervision by the employer" means that only the employer or a designated responsible person, such as the supervisor or foreman qualified by experience or training will control the operation of the press to prevent its use by unauthorized persons. When the press is not in use, it must be locked off, either by a keyed selector or locking out of the main power disconnect. The keys must remain in the custody of a responsible person. The main disconnect switch can be considered as the off position of the press but the selector must be of the key type.

2. In view of the continuous run position being eliminated from your presses, the requirement of 29 CFR 1910.217(b)(7)(viii), prior action or decision by the operator before actuation is not required. All control wiring should be completely removed from the continuous run position of the selector to assure complete deactivation of this control. The top yellow stop button is not an OSHA requirement but an emergency red stop button is required in accordance with 29 CFR 1910.217(b)(7)(ii).

3. When a foot control is provided, the selector method between hand and foot control must be of the key type and installed in a location separate from the stroking selector. A foot pedal and linkage is an alternative to the key selector, which can be removed by the responsible person when hand control is desired.

4. Pull-outs are recognized methods of safeguarding. Control systems and brake monitors are required only when press operations meet the conditions as outlined in 29 CFR 1910.217(c)(5).

5. Two hand controls may be used for dual service; i.e., for run and inch operations. The requirements of 29 CFR 1910.217(b)(13) and (14) do not apply to inching controls and there is no requirement to figure stop time and safe distance for this operation; however, a safe distance is needed for effective protection.

6. When pull-out devices are used as the method of safe guarding, a thorough inspection of the systems and mechanisms will suffice. Therefore, the stop time measuring device is not required.

Hopefully, this information and the enclosed booklet, "Interpretation of ANSI B11.1(1971), Safety Requirements For the Construction, Care, and Use of Mechanical Power Presses," will be helpful in complying with these standards.

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

Sincerely,



John K. Barto,
Chief Division of
Occupational Safety Programming