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.

May 7, 1976

Subject: 29 CFR 1910.261(a)(1), (2) and (4), Mills and Calendars in the Rubber and Plastics Industries

This is in response to a letter from your office, dated February 25, 1976, concerning a request for written confirmation of Mr. Gier's telephone conversation with Mr. Childs on February 10, 1976.

All mills in the Rubber and Plastics Industries installed prior or subsequent to August 31, 1971, are required to be installed so that the top of the operating rolls is not less than 50-inches above the level on which the operator stands, irrespective of the size of the mill. However, to alleviate the burden of extensive changes, mills contracted for prior to August 31, 1971, shall be brought into compliance when any major modification or relocation of existing installations takes place.

If I may be of any further assistance, please feel free to contact me.

Barry J. White
Associate Assistant Secretary
for Regional Programs