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 https://www.osha.gov.

June 30, 1983

Mr. W. Michael Bierbower
Armstrong World Industries, Inc.
Liberty Street - Floor Plant
Lancaster, Pennsylvania 17604

Dear Mr. Bierbower:

Thank you for your letter of June 12, 1983, regarding your proposal for use of an emergency jog reverse control during mill rescue operations.

The proposed installation of a unique manually operated emergency jog reverse control on the mills at the Armstrong facilities is an acceptable concept. The OSHA General Industry Standard, 29 CFR 1910.216 does not prohibit such a concept. The emergency switches referred to by 29 CFR 1910.216(e) pertain to the various emergency stop switches. Therefore, the intentional reactivation of a machine by a rescuer, through the aid of an emergency reverse jog control, is acceptable in some rescue circumstances.

Easy and quick extrication of employees who may become caught in the in-running bites of mill or calender rolls is necessary. In order to eliminate additional injury which may result from reversing the rolls, roll separation procedures are recommended prior to roll reversal. Of course, where hot work is performed, the harmful effects of heat exposure may be of greater concern.

Emergency roll separation is the preferred method for extricating employees. It may be accomplished through the use of normal roll-spacing mechanisms or with adaptation of special equipment such as air-operated pull-out spacers. It is recommended that emergency roll separation techniques be investigated and, where possible, implemented in addition to the proposed emergency job reverse control.

Thank you for sharing your thoughts and concepts with us. If we may be of further assistance, please feel free to contact me.


John K. Barto
Chief, Division of Occupational
    Safety Programming