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.

July 13, 1978

MEMORANDUM FOR:     MILAN RACIC
                    ACTING REGIONAL ADMINISTRATOR - CHICAGO

THRU:               DONALD E. MACKENZIE Field Coordinator

FROM:               BRUCE HILLENBRAND Acting Director, Federal Compliance
                    and State Programs

SUBJECT:            Duplex Rewinder Bar Guards

The subject bar guards based on your information and the pictures provided, appear to meet the requirements described in 29 CFR 1910.261(l)(9)(i); however, alteration or misapplication of an otherwise adequate Bar Guard could easily create a hazardous condition to exposed employees. For the above reason, the compliance of the bar guards with 29 CFR 1910.261(l)(9)(i) can only be determined by the safety and health professionals observing it actually in use under the specified job condition.