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.

January 10, 1977

 
MEMORANDUM TO: ROBERT C. TICE
REGIONAL ADMINISTRATOR
 
Subject: 29 CFR 1910.217, Guarding of Punch Presses The Williamhouse of Texas
 
ATTENTION: C. R. HOLDER
 

The fact that the ANSI B11.I Committee did not intend for the standard to apply to low hazard industries such as the Engraved Stationery Manufacturers, does not exclude all users of presses from 29 CFR 1910.217 because their operations are not metal working. The engraved stationery business does have a definite problem of fixed barrier guarding due to the need for hand feeding. The Williamhouse of Texas photos indicate that the presses are equipped with an automatic feed negating the need for operators to place their hands or fingers near the point of operations. Therefore a fully enclosed fixed barrier guard appears to be feasible.

Since there may be some uncertainty as whether 29 CFR 1910.217 does apply to presses in the envelope manufacturing industry, it is advisable to use 29 CFR 1910.212 for citing.

ANSI B169.1-1975, Safety Requirements For The Construction, Care And Use Of Machinery Used In Envelope Manufacturing, Paragraph 7.1.6, establishes the guarding requirements for Open-window Die Presses.

Richard P. Wilson
Acting Director of Federal
Compliance and State Programs