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 20, 1994

Mr. Michael J. Siris
Attorney at Law 1615 Northern Boulevard
Manhasset, New York 11030

Dear Mr. Siris:

This is in further response to your letter of August 22, requesting an interpretation of the Occupational Safety and Health Administration (OSHA) standard, 29 CFR 1910.212(a)(3)(ii), in regards to its applicability to guard an area above the ram/piston on a vertical hydraulic downstroke/trash compactor.

The enclosed OSHA standard, 29 CFR 1910.212(a)(3)(ii) requires that, in the absence of applicable specific standards, a guard must be designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle. Specifically, the OSHA standard requires that the vertical hydraulic downstroke/trash compactor must have a guard above the ram/piston if any part of the operator's body is exposed to the danger zone during the operating cycle.

We appreciate your concerns regarding occupational safety and health in the workplace. If we can be of further assistance, please contact [the Office of General Industry Enforcement at (202) 693-1850].


John B. Miles, Jr.,
Director Directorate of Compliance Programs

[Corrected 4/8/08]