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.

September 9, 1976

Mr. O. V. Simons, Senior
Engineering
American Mutual Insurance Companies
Suite 501
4415 Harrison Street
Hillside, Illinois 60162

RE: Your letter dated August 10, 1976 - 1910.107, Spray Finishing and 1910.217, Mechanical Power Presses

Dear Mr. Simons:

You asked if the use of cardboard panels laid over a concrete floor in a spray booth would be permitted. You stated the cardboard would be replaced daily. Our answer is that this would not be permitted.

As discussed with Mr. Fred Stockmeier of this office, your second question was concerned with the requirements of the mechanical power press standard as it relates to foot controls. During the discussion of your assured's operation, the guarding of the point of operation arose. It appears that guarding may or may not be used according to the particular set of dies being used. Also, the use of foot or hand controls depends upon the dies being used. These variables make it almost impossible to provide an answer to your problem. If foot controls are used, a positive means must be used to keep the employees' hands out of the danger zone. If hand controls are used, they must be placed in accordance with the safety distance requirements. If the employees place their hands between the dies to load or unload on a part revolution clutch press, a brake monitor is required.

Because of the variables involved, we hesitated to give you a firm answer. We are enclosing a brochure describing Triton College's on-site consultation service. Perhaps your assured would consider using this service. Triton's safety engineers, after viewing the operation, could probably provide positive answers to the various questions.

Please contact us if we can be of further service.

Very truly yours,



NICHOLAS DiARCHANGEL
Acting Regional Administrator
for Occupational Safety and Health