Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

January 14, 1977

Mr. C. Zeilenga
Manager Product Reliability Verson
Allsteel Press Company
Chicago, Illinois 60619

Dear Mr. Zeilenga:

This is in response to your letter dated November 8, 1976, concerning your request for clarification of 29 CFR 1910.211(d)(8) and (17), in the meaning of concurrent when related to two-hand controls on Mechanical Power Presses.

Concurrent as used in the standards, means the use of both hands and has no relation to simultaneous or any other time element. Within the intent of the standards, there is no requirement that the anti-tiedown feature be provided although tie-downs and bridges are in violation of concurrent use of both hands.

This clarification is not intended to mean that all power press operations with two-hand controls are safe without an anti-tiedown feature, especially those where the two-hand controls are located within arms reach of the point of operations. If this condition is encountered and a serious injury may occur from the hazard, a serious citation may be issued under Section 5(a)(1) of the Occupational Safety and Health Act.

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


Donald A. Shay,
Director Office of
Compliance Programming