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 https://www.osha.gov.

March 21, 1977

Mr. Edwin C. Clouse, Jr.
26-12th Avenue W.
Albia, Iowa 52531

Dear Mr. Clouse:

Your letter dated January 20, 1977, addressed to the President, has been referred to this office for reply.

The point of operation hazard on power press brakes has been evident for many years. The hazard has left hundreds of employees with handicaps from severed hands, arms and in many cases resulted in death when other parts of the body were caught in the point of operation.

As you know, the only way to completely eliminate the point of operation exposure to employees is to fully enclose the danger area with a fixed barrier guard. This type of guard prevents them from placing any part of their bodies into the point of operation but in many cases interferes with the operation to a degree that production is impractical.

The Occupational Safety and Health Administration (OSHA) recognized this problem and provided more than one method of safeguarding in 29 CFR 1910.212 of the Safety Standards for General Industry (copy enclosed). In addition, an OSHA Program Directive (PD) #100-44 (Revision #1)(copy enclosed), dated October 26, 1976, was issued to clarify the guarding requirements.

One of the many acceptable methods of safeguarding is the electric light curtain or electric eye, providing that it is located far enough away to stop the machine before an employee can reach into the point of operation. The installation of the electric eyes was apparently the decision of your employer to provide you with the best possible protection.

Hopefully, this information will be helpful to you and your fellow employees. If I may be of any further assistance, please feel free to contact me.


Bert M. Concklin
Deputy Assistant Secretary of Labor