Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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



June 8, 1983

Mr. C. W. Penake
Vice President
Penake Tool & Die Company
1055 Custer Drive
Toledo, Ohio 43612

Dear Mr. Penake:

This is in further response to your letter dated April 5, 1983, concerning the guarding of flywheels on power presses.

The Occupational Safety and Health Administration's General Industry Standards 29 CFR 1910.219(b)(1) and (b)(1)(vi) require guarding of the press flywheel. Furthermore, the latter provision requires that flywheels above working areas be provided with guards of sufficient strength to contain the flywheel in the event of shaft or wheel mounting failure.

Reference to ANSI 815.1-1972, the current version of the source standard, rapidly demonstrates that structural failures are possible. Appendix AB.1 of ANSI 815.1 indicates that failures of a fatigue nature can be anticipated, particularly for older machines that have been continually exposed to cyclic leads. Therefore, substantial guarding is necessary to provide safety.

That company die setter's need to have easy access to the flywheel for die-setting for is completely valid and should be a major consideration of the guarding provided. In that regard, the guard configuration enclosed is recommended for consideration.


John K. Barto
Chief, Division of Occupational
Safety Programming