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.

February 23, 1978

                Regional Administrator

THRU:           DONALD E. MACKENZIE Field Coordinator

FROM:           RICHARD P. WILSON Deputy Director Federal Compliance and
                State Programs

SUBJECT:        Compression Springs Requirements, 29 CFR 1910.217(b)(3)(ii)
                and 29 CFR 1910.217(b)(4)(iii)

This is in response to your letter of September 28, 1977, regarding a request for comments and guidelines concerning the use of tension springs in lieu of the required compression springs on power presses. It further confirms discussions between Mr. Nunez and Mrs. Preston on this subject.

Our research reveals that the requirement originated years ago in the National Consensus Standard with the theory that compression springs are more reliable than tension springs. However, there are no documents available to support this requirement.

In view of the fact that the standard requirements for compression springs are not supported and the tension springs appear not to present a hazard, the employer has complied with the intent of the standards. Therefore, the situation would be considered a de minimis violation.

A copy of your correspondence and this response are being forwarded to the Directorate of Safety Standards Programs for information purposes.