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 https://www.osha.gov.

August 11, 1975


SUBJECT:             29 CFR 1910.21(b)(13), Simple Test: definition of

This memorandum is in response to your letter dated June 20, 1975, requesting concurrence with your interpretation to Mr. Jerry L. Addy, Commissioner, Iowa Bureau of Labor, Des Moines, Iowa, concerning the subject definition.

In your interpretation of "simple test" to Mr. Addy, you state that it, "would be any action that the employer can take to either deactivate the control system or to create a failure in some part of the control system, and then demonstrate, (1) that normal press stopping has not be affected and, (2) the initiation of a successive stroke is not possible until the purposely introduced test failure has been corrected." This is a comprehensive definition and any attempt to elaborate or expand on this definition would result in setting forth procedures for all machines that may not always be applicable. Therefore, the intent of this standard is to allow the employer to establish his own testing procedures that will satisfy these requirements.


Barry J. White
Associate Assistant Secretary
for Regional Program