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.

September 7, 1990

MEMORANDUM FOR:     LINDA R. ANKU
                   REGIONAL ADMINISTRATOR

THROUGH:            LEO CAREY, DIRECTOR
                   OFFICE OF FIELD PROGRAMS

FROM:               PATRICIA K. CLARK DIRECTOR DESIGNATE DIRECTORATE OF
                   COMPLIANCE PROGRAMS

SUBJECT:            Feasibility of Guarding ESCO Swaging Presses

The safeguarding of the subject ESCO swaging presses, discussed by your correspondence of September 8, 1989, has been reviewed by my staff. We apologize for the delay in our response.

Safeguarding of the point of operation is deemed to be feasible, if a holding fixture is devised to position and support the wire rope while it is placed in the dies, and a two-hand control is used to activate the press. The use of a two-hand control for safeguarding the operator becomes possible with the use of a wire rope positioning and restraining fixture.

Even when some present operations may provide for guarding by location, the consistent use of a holding fixture with two-hand control operation would provide for employee safety under any circumstances.

A review of the video tape demonstration of the 500 ton swaging press operation indicates that the need for guarding while swaging smaller gage wire rope, such as demonstrated, is not required. The operator's hands are fully occupied during the pressing and are at a safe location. The forces exerted by the rope upon the operator appear to be small. However, when large gage wire rope is handled, the use of a holding fixture, which constitutes effective guarding, is justified.

We concur with your position concerning the "slow" movement of the press ram and the potential for only an occurrence of "pinched fingers". The work environment in combination with the current procedures used for swaging can be anticipated to eventually result in an injury more severe than pinched fingers. Due to the strong forces required to manually constrain and manipulate heavy gages of wire rope while positioning the assembly in the swaging press, it can be anticipated that the worker could be injured by the moving ram during the swaging process. Any lack of coordination (e.g., due to fatigue) by the operator would contribute to the probability of injury.