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.

December 20, 1979

Mr. J. B. Lauritzen, Jr.
Manager, Environmental and Industrial Engineering
Western Electric
222 Broadway
New York, New York 10038

Dear Mr. Lauritzen:

This is in response to your letter regarding the Mechanical Power Press Standard 29 CFR 1910.217.

The requirements of 29 CFR 1910.217 regarding the concerns expressed in your letter are as follows:

1. Automatic coil-fed mechanical power presses are not required to be equipped for control reliability and brake monitoring if:

a. Die area barrier guards are fixed, or are interlocked to deny entry until after slide motion has stopped.

b. Pneumatic or mechanical stock grippers are used to remotely restrain and guide coil end stock being fed into fully automated power presses which are guarded so as to permit no exposure to the die area while the operator actuates the press in the inch mode.

2. Inspection requirements of 1910.217(e)(1)(ii) are complied with if:

a. Press adjustments and modifications, accomplished frequently each week, verify the performance of the clutch brake mechanism, anti-repeat feature, and single stroke mechanism.

3. The standard does not specify a duration for records retention, however, we recommend your weekly inspection records associated with the power presses be retained for review for a period of not less than six months.

4. It is not necessary to equip a mechanical power press with control reliability or brake monitors as stipulated by 1910.217(b)(13) and 1910.217(b)(14), when the press is set up to operate in a fully automatic mode and employees under any operational circumstances are protected from exposure to the die area hazards, during powered operation of the press. Where no employee exposure to the hazards of the die area is possible, the technical violation may be de minimis. (Please refer to enclosure regarding de minimis violations.)

We have enclosed copies of current OSHA Directives which effect the safe operation of power presses. If we may be of further assistance, please feel free to call or write.

Sincerely,



Grover C. Wrenn Director,
Federal Compliance and State Programs