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.

November 19, 1980

Mr. Chris McKinnell
General Manager
Pressmation Inc.
522 Cottage Grove Road
Bloomfield, Connecticut 06002

Dear Mr. McKinnell:

This is in response to your inquiry concerning a letter from this office to the Rockford Safety Equipment Co., and confirms a conversation with a member of my staff.

Our response was specifically related to whether an electro-mechanical single stroke device fulfills the requirement for a single stroke mechanism under 29 CFR 1910.217(b)(3)(i). A copy of our response to Rockford Safety Equipment Co. is enclosed. In our response, we indicated that for such a device the intent of 29 CFR 1910.217(b)(13), control reliability, should be a primary consideration. We recognize that 1910.217(b)(13) is not directly enforceable with regard to full cycle power presses; however, employers are obligated under the general duty clause, 5(a)(1) of the Act, to provide a workplace free of recognized hazards. An electro-mechanical single stroke mechanism which effects the safety of employees who are exposed to point of operation hazards, should assure fail-safe operation and prevent the initiation of a successive stroke when a failure of the electro-mechanical device occurs. To that extent, employers are well advised to be aware of the stipulations of 29 CFR 1910.217(b)(13).

If I can be of further assistance, please call or write.

Sincerely,



John K. Barto
Chief, Division of
Occupational Safety Programming