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 13, 1994

Dick Kozyra, President
American Bakers Cooperative, Inc.
122 Randolph Ave., Suite 202
P.O. Box 308
Clifton, NJ 07001

Dear Mr. Kozyra:

This is in further response to your May 31, letter requesting interpretation of the Bakery Equipment Standard, 29 CFR 1910.263(l)(9)(iv)(a). Please accept our apology for the delay in re-sponding.

You requested clarification for ovens with time delay relay systems built into the power supply line, which is interlocked with the fuel safety valves. Specifically, you asked if all gas safeties, when tripped, must cause the gas safety valves to close immediately, or is a time delay legal?

The standard does not allow employers to install time delay relay systems in the power control line of ovens, when the power line is interlocked with the fuel supply.

The high-tension current for any electric spark-type ignition device must originate in a power supply line which is interlocked with the fuel line supply for the oven in such a way that in case of current failure both the source of electricity to the high tension circuits and the fuel supply shall be turned off simultaneously.

We appreciate your interest in employee safety and health. If we can be of further assistance please contact Mr. Russelle R. McCollough in the Office of General Industry Compliance Assistance, telephone number (202) 219-8031, extension 105.

Sincerely,

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