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.

December 24, 1991

Cheryl A. Hansen
Engineering Reference Librarian
Triodyne, Inc.
5950 West Touhy Avenue
Niles, Illinois 60648

Dear Ms. Hansen:

Thank you for your letter of September 5, concerning mechanical power press requirements and the requirements applicable to platen presses.

Replies to the four questions as follows:

Question #1. "Is control reliability and brake

monitoring required on a mechanical power press equipped with a pull-out device?" ("Specifically ... in the time periods of 1981 and 1987.")

Question #2. Concerning the definition of power

press at 29 CFR 1910.211(d)(46), "is cardboard considered other material?"

Question #3. "Are platen presses included under

29 CFR 1910.217?"

Question #4. "What section of OSHA applies to

point of operation guarding for platen presses during the time periods of 1981 and 1987?"

Reply: #1. Control reliability and brake monitoring are not

required on a mechanical power press equipped with a properly installed and adjusted pull-out safety device as stipulated at 29 CFR 1910.217(c)(3)(i)(b) and (c)(3)(iv). 29 CFR 1910.217(c)(5) stipulates only those instances where control reliability and brake monitoring are required. This standard has been continuously in effect since 1978.

Reply: #2 Under the definition at 29 CFR 1910.211(d)(46),

cardboard is considered "other material" on which a mechanical power press might impart work, such as cutting.

Reply: #3 Platen presses are not included under the

regulation at 29 CFR 1910.217. OSHA has never modified the standard to specifically exclude platen presses since it was deemed to be unnecessary considering the distinct difference between platen presses and mechanical power presses. Furthermore, the OSHA Instructions had addressed the situation.

Reply: #4 Platen presses are regulated by the Occupational

Safety and Health Administration (OSHA) at 29 CFR 1910.212(a)(1),(2) and (3). This section of the OSHA standards has been the appropriate regulation for platen presses since the inception of the standards in 1971. OSHA Instruction STD 1-12.7, dated October 30, 1978 (issued earlier as #100-34, dated July 18, 1975,) was issued to clarify the applicability of 29 CFR 1910.212 to platen presses.

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

Sincerely,



Patricia K. Clark, Director
Directorate of Compliance Programs