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.

April 29, 1982

MEMORANDUM FOR:     CURTIS A. FOSTER
                   REGIONAL ADMINISTRATOR

THRU:               JOHN MILES, DIRECTOR
                   FIELD COORDINATION

FROM:               PATRICK R. TYSON
                   DIRECTOR, FEDERAL COMPLIANCE
                     AND STATE PROGRAMS

SUBJECT:  An Interpretation of 29 CFR 1910.217(b)(3)(i) as requested

Although 29 CFR 1910.217(b)(3)(i) requires the installation of a single stroke mechanism on full revolution mechanical power presses, the absence of the device may be classified as a de minimis violation if all the following circumstances prevail:

1. The point of operation is completely enclosed with an effective fixed barrier guard, and is in full compliance with 1910.217(c)(2)(i)(b).

2. Process material is automatically or mechanically fed into the point of operation (Mechanical feeds could utilize semi-automatic fixturing).

3. There is no actual or potential employee exposure to the point of operation, per FOM Chapter VIII paragraph 3.

4. Die setters are safeguarded in conformance with OSHA Instruction STD 1-12.24, primarily paragraphs E.3 and E.4.