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.

September 17, 1993

Charles A. Carlsson, Secretary
ANSI B11 Standards Committee
The Association For Manufacturing
7901 Westpark Drive
McLean, Virginia 22102-4269

Dear Mr. Carlsson:

This is a further response to your letter of August 6, addressed to Mr. David Ziegler, Acting Assistant Secretary of Labor of the Occupational Safety and Health Administration (OSHA), in which you requested that OSHA issue a field directive to clarify that "eyelet machines" and similar type "four-slide machines" are covered by the 29 CFR 1910.212, Machine Guarding standard, rather than by the 1910.217, Mechanical Power Presses standard.

As you are probably aware, OSHA Instruction STD 1-12.21 of October 30, 1978, was issued to provide uniformity in interpretation and application of 29 CFR 1910.217 to those mechanically powered machines that shear, punch, form or assemble metal or other material by means of cutting, shaping or combination by dies attached to slides. Paragraph 4(a)(1) of the above-mentioned Instruction provides guidance on the recognition of particular machines as mechanical power presses under the standard. A copy of the Instruction is enclosed for your information.

OSHA is aware that there are many machines that perform the above-mentioned functions but are not mechanical power presses, and thus are excluded from the requirements of 1910.217. ANSI recognized this in its Scope provision of B11.1. Since the source standard of OSHA's 29 CFR 1910.217 is ANSI B11.1-1971, and since it was ANSI's intent to exclude "eyelet machines" and similar type machines sometimes referred to as "four-slide machines" from the requirements of B11.1, then OSHA, too, will recognize this exclusion.

OSHA Regional Administrators will be notified, through memorandum, that "eyelet" and "four-slide" machines are not covered under 1910.217, but rather by the requirements of 1910.212.

If we can be of further assistance, please feel free to contact Mr. James C. Dillard of my staff, at (202) 219-8031.





Roger A. Clark, Director
Directorate of Compliance Programs