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.

June 24, 1980

John E. McAllister, President
Rockford Safety Equipment Co.
4620 Hydraulic Rd.
P.O. Box 5166
Rockford, Illinois 61125

Dear Mr. McAllister:

This is in response to your request for a clarification of Subpart O of 29 CFR 1910, regarding single stroke mechanism as used on full revolution mechanical power pressures.

As you are aware, the standard does not define a specific device to achieve single stroke capability. As a matter of fact, 29 CFR 1910.217(b)(3)(ii) specifically infers that more than one form of device is acceptable. Your interpretation and understanding of the use of the word "arrangement" in the definition of 1910.211(d)(50) is valid. There is no requirement that the arrangement be specifically a mechanical device.

The language as stated by the standard is not intended to limit or inhibit the application of improved methods by which single stroke is achieved. However, in defense of mechanical devices we would like to offer the following:

1. Mechanical devices are normally less expensive to purchase and install.

2. Qualified employees to perform installation and service are rarely a problem to the employer.

3. Although service life between service and repair is shorter than competing methods, the relative simplicity of the mechanical devices must be considered.

4. Their condition can be visually examined during each servicing or inspection of the press, thereby assuring reliability and the intent of the standard.

The electro-pneumatic single stroke packages to which you refer would provide the protection required by the standard where they are properly applied, maintained, and provide inherently fail-safe capability within the intent of 29 CFR 1910.217(b)(13). Additionally they can provide various alternatives and expanded capabilities to the safe operation of the press.

OSHA standards require minimum acceptable criteria for safety. Therefore, the decision as to which type of device is appropriate in any specific situation is left to the considered opinion of the employer.

If we may be of further assistance, please feel free to call or write.

Sincerely,



John K. Barto Chief,
Division of Occupational Safety Programming