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.

May 1, 1991

Alex C. Smart
Ass't Vice-President/Eng'r
Corporate Engineering
46 North First Street
Fulton, New York 13069-1299

Dear Mr. Smart:

This is in response to your letter of February 25, in which you requested confirmation of an interpretation on 29 CFR 1910.212(a)(3)(ii) and 1910.2261(k)(18), as a result of a telephone conversation with Jeff Finch, of my staff.

Your concerns specifically addressed calender stacks used in the pulp and paper industry. 1910.261(k)(18) addresses the hazard of nip points on calender rolls and gives alternatives as to the method of eliminating or minimizing this hazard. The abatement methods listed in the standard would be acceptable so long as exposure to the hazard is eliminated or minimized. The standard contained in 1910.261(k)(18) is specific to the hazard of nip points on all calender rolls in pulp, paper, and paperboard mills. However, nip point hazards, when paper is not being fed into the calender stack rolls, shall be guarded in accordance with a general standard such as 1910.212, which does apply in such a situation.

We hope this helps to clarify your concerns. Your interest in workplace safety and health is appreciated.


Patricia K. Clark, Director
Directorate of Compliance Programs