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.

JAN 8 1991

Mr. Ronald D. Schaible, CIH
Manager,
Corporate Safety
and Industrial Hygiene Department
P.O. Box 3608
Harrisburg, Pennsylvania 17105-3608

Dear Mr. Schaible:

This is in response to your letter of November 2, regarding the AMPOMATOR CLS II Wire Terminal Machine, and whether in our opinion, point of operation guarding is required. We apologize for the delay in this response.

Members of our staff reviewed the submitted material, which clearly showed an automatic operation, with the point of operation located in a position that would be difficult for an employee to reach. The point of operation was small enough to prevent fingers from easily gaining access. In addition, the interlock switch on the main control box, as well as a main power disconnect, capable of being locked out, add to the safe operation of this machine. Considering all of the above we would concur that no point of operation guarding appears necessary. However, the opinion given here should in no way be construed as a blanket waiver on this machine from the point of operation requirements. Occupational Safety and Health compliance officers must evaluate each situation they encounter and apply the standard accordingly.

Your interest in safety and health is appreciated. If we may be of further assistance, please do not hesitate to contact us.

Sincerely,



Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

GICA:SAA:JFinch:file #saa.610 corliss comp. cc:Clark,Donnelly,Stroup,Finch,HRT,OTI,OCIS,CHRON