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.

November 7, 1975

Mr. Charles S. Jones
Safety Supervisor
FMC Corporation, Chain Division
220 South Belmont Avenue
Box 346B
Indianapolis, Indiana 46206

Dear Mr. Jones:

This is in response to your letter dated September 30, 1975, concerning direct drive presses.

Within the definition of "direct drive", in 29 CFR 1910.211(d)(7), direct drive presses match the same operational characteristics of "part revolution clutches." Therefore, since direct drive is classified with part revolution it shall meet the requirements contained in 29 CFR 1910.217(b)(7) (Mechanical Power Presses) by having a self-engaging brake that is activated when the drive is disconnected.

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

Sincerely,

John K. Barto, Chief
Division of Occupational
Safety Programming