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.

February 22, 1978

Mr. William H. McManus
Executive Vice President
Envelope Manufacturers Association
1 Rockefeller Plaza
New York, New York 10029

Dear Mr. McManus:

This is in response to a request from the Kansas City Regional Administrator, regarding clarification of an interpretation given by Mr. John A. Proctor to the Envelope Manufacturers Association dated January 27, 1975.

Paragraph two of the letter of interpretation states:

The OSHA Standards for mechanical power presses in Section 1910.217 do not apply to several types of papercutting machines used by your industry. Compliance with the requirements for safeguarding of the point of operation found in Section 1910.212 is mandatory. Machinery for blanking, trimming, punching, and drilling of paper must be safeguarded in accordance with Section 1910.212.

The preceding interpretation means that machines specifically designed for the purpose of blanking, trimming, punching, and drilling of paper are not considered the same machines as those used in the metal industry and commonly referred to as mechanical power presses. Therefore, the machines shall be safeguarded in accord with OSHA standards, Section 29 CFR 1910.212. However, if mechanical power presses (the type used in the metal industry) are used in the envelope manufacturing industry, the presses shall be safeguarded in accord with OSHA standards, Section 29 CFR 1910.217.

OSHA uses National Consensus Standards as a guideline in conjunction with 29 CFR 1910.212, general requirements for all machines. Therefore, "American National Standard Safety Requirements for the Construction, Care, and use of Machinery used in Envelope Manufacturing," ANSI B169.1-1975, will be used as a determining factor.

I hope the preceding information clarifies any misunderstanding that might have occurred concerning the letter of interpretation dated January 27, 1975. Should there be any questions, please contact the Division of Occupational Safety Programming, Attention Ms. Preston, Telephone: 202-523-8136.

Thank you for your concern and continuing interest in occupational safety and health.


Richard P. Wilson
Deputy Director,
Federal Compliance and State Programs