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.

May 27, 1986

Mr. Donald Cejer
TRIAD Controls Inc.
RD. No. 1, Box 353B
Hookstown Grade Road
Clinton, Pennsylvania 15026

Dear Mr. Cejer:

This is in response to your letter to Mr. Dick Bradley and confirms a telephone discussion with Mr. Bode, a member of my staff. Your letter addressed the safeguarding of power press brakes and requests a definition of "Safe Distance".

As you are aware, the Occupational Safety and Health Administration (OSHA) requires that power press brakes be safe-guarded per 29 CFR 1910.212(a), copy enclosed. Point of operation safeguarding must comply with 29 CFR 1910.212(a)(3)(ii). OSHA generally accepts the safeguarding specifications delineated by the American National Standards Institute, Inc. (ANSI) for power press brakes as being the appropriate standard. The current standard is ANSI B11.3-1982.

Under the requirements of ANSI B11.3-1982, an employer may use the concept of a safe distance only when safeguarding cannot be achieved with a point of operation guard or device, per Section 6.1.4(1). Additionally, the material position gage (back stop) is also required to be used during all such procedures. Although the ANSI standard committee could not agree upon a dimension for safe distance, OSHA has established a value for it. Safe distance is the distance from the lower die to the edge of the material. Safe distance may not be less than the measured distance on the operator's hand from the juncture of the thumb and hand to the tip of the longest finger plus 1 inch, but not less than 6 inches.

OSHA has not issued a directive concerning safe distance as it applies to point of operation safeguarding or power press brakes. However, a memorandum concerning these machines was issued on March 25, 1983, a copy of which is enclosed. Should you desire to discuss this issue in greater depth, please contact [the office of General Industry Enforcement at 202 693-1850].

[This document was edited on 9/26/2002 to strike information that no longer reflects current OSHA policy. Please see the 2/14/97 Directive CPL 02-01-025 "
Guidelines for Point of Operation Guarding of Power Press Brakes" for the current OSHA policy.]

If we may be of further assistance, please contact us.

Sincerely,


John B. Miles, Jr., Director
[Directorate of Enforcement Programs]

Enclosures

[Corrected 6/2/2005]

 


October 15, 1985

U.S. Dept. of Labor
OSHA
5360 Genesee Street
Bowmansville, NY 14026

Attn: Mr. Dick Bradley, Area Director

Subject: Point of Operation Guarding for Power Press, Brakes

Dear Mr. Bradley:

I, along with other members of the safeguarding community are of the understanding that power press brakes must be guarded under the requirement of 1910.212 of the Federal Standards.

However, in recent months several of my industrial accounts have commented about an OSHA directive accepting "Safe Distance" as an alternative to to point of operation guarding. Others have also indicated that citations were issuedon press brakes that were not being used at the time of the OSHA inspection. The owners considered these press brakes to be in compliance and will not equip them with point of operation guarding.

In order to avoid misinterpreting the directive or misleading our customers, I would appreciate a written clarification of OSHA's current position on press brake guarding which should clarify when a "Safe Distance" is determined, and what is a "Safe Distance". A copy of the directive would also be helpful.

Thank you in advance for your prompt response.

Sincerely,

Ronald Cejer