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 9, 1982

MEMORANDUM FOR:     ALL REGIONAL ADMINISTRATORS
                   AND AREA DIRECTORS

THRU:               JOHN B. MILES DIRECTOR, 
                   OFFICE OF FIELD COORDINATION

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

SUBJECT:            Utilization of a Stop Time Measuring Instrument for
                   Verification of Compliance With 29 CFR 
                   1910.217(c)(3)(iii)(e) and .217(c)(3)(vii)(c)

A special seminar was conducted at the OSHA Institute during the week of November 22, 1982, regarding the use and application of newly acquired Semelex Stop Time Measuring Instruments. These instruments were acquired to permit a valid determination of safety distance as it pertains to part revolution mechanical power press safety.

Proper utilization of the instrument requires that only trained personnel conduct the evaluation of power press stop time and safety distance analysis. Therefore Area Directors should contact a trained individual from their respective region when workplace evaluations are necessary. The list of trained attendees at the Institute Special Seminar is attached for convenience. Due to the limited availability of instruments intra-regional coordination is necessary and inter-regional cooperation encouraged.

Field evaluation of the applicability and usefulness of this instrument was conducted during the last three years. The evaluation showed employer and employee acceptance.

Proper use of the instrument yields valid evaluation of the employers compliance with 29 CFR 1910.217(c)(3)(iii)(e) and .217(c)(3)(vii)(c). Since "safety distance" is a very critical factor effecting the safety of numerous employees full utilization of the instruments is desired.

Currently, ten instruments have been deployed to the field and are in the possession of the noted seminar attendees. Additional field compliance personnel should be trained in the proper use of the instrument by the various seminar attendees. It is anticipated that, future OSHA Institute training will be integrated into the power press safety course.

Should special inquiries and/or unique problems or applications develop, field personnel should contact Joseph Bode in the Division of Occupational Safety Programming at the National Office, (FTS) 523-8124 for assistance.