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.

September 23, 1980

S.A. Brennen, President
PSC Corporation
Industrial Control Division
6880 Orangethorpe Avenue Buena Park, California 90620

Dear Mr. Brennen:

This is in response to your correspondence regarding a power press brake used as a mechanical power press (punch press).

Punch presses are regulated under 29 CFR 1910.217, Mechanical power presses. OSHA does not currently apply the mechanical power press standard to power press brakes. However, OSHA does require safeguarding similar to that which is required by 29 CFR 1910.217. OSHA regulates power press brakes under 29 CFR 1910.212, and applies the recommendations of ANSI B11.3-1973.

Employers are well advised to consider the options of 1910.217 and those provided by the ANSI committee in their draft revision of 1978, when evaluation safeguarding requirements and procedures. The ANSI committee currently considers straight sided power press brakes using four of more gib points gib points as being regulated under ANSI B11.1, Safety Requirements for Mechanical Power Presses.

It is our opinion that the standard clearly defines the employer's responsibility to effectively safeguard his machines. 29 CFR 1910.212 establishes the criteria for machine safeguarding so as to prevent employee injuries.

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

Sincerely,



John K. Barto, Chief
Division of Occupational Safety Programming