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.

April 15, 1991

MEMORANDUM FOR:     REGIONAL ADMINISTRATORS

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

THRU:               LEO CAREY, DIRECTOR 
                   OFFICE OF FIELD PROGRAMS

SUBJECT:            Clarification of Scope of OSHA Instruction STD 1-12.22

It has come to our attention that the scope of the action section of OSHA Instruction STD 1-12.22 needs clarification in order to assure uniform application in the field. The subject of the instruction is 29 CFR 1910.212(a)(3)(ii) Point of Operation Guarding for All Machines; As Applied to Hand-Fed Engraving Presses Used in the Engraved Stationary Manufacturing Industry.

Paragraph 4. Action in OSHA Instruction STD 1-12.22 applies only to hand-fed engraving presses used to apply ink to the underside of paper. It does not apply under any other conditions. For example, it does not apply when engraving takes place without the use of ink. For another example, it does not apply when materials other than stationery are being engraved. It also does not apply when engraving is not being performed.

For situations involving engraving presses where Paragraph 4. Action of OSHA Instruction STD 1-12.22 does not apply, the full scope of 29 CFR 1910.212 is applicable.