Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

April 23, 1997



FROM:               JOHN B. MILES, JR., DIRECTOR

SUBJECT:            Request for Compliance Assistance on High Profile Case

This is in response to the subject request of your February 4 memorandum to which was attached a copy of a February 3 memorandum to you from your Houston North Area Office. We apologize [for] the delay in our response. You requested that we provide answers to the following two questions posed in the memorandum from the Houston North Area Office. Our replies follow.

Question 1: The inspected equipment falls under paragraph

1910.218(f), covering forging presses. Paragraph 1910.218(f)(2) requires lockout/tagout. If the employer is deficient in elements of the requirements for LO/TO, can the applicable sections of 1910.147 be cited as well (i.e., training, verification, application of locks, etc.)?

Reply: OSHA intended that pre-existing standards, including paragraph 1910.218(f)(2), that require specific types of machines to be locked out, would be supplemented and not replaced by 1910.147. Section 1910.147 therefore also applies and can be also cited as to hydraulic forging presses which are covered under paragraph 1910.218(f)(2). This is discussed in the preamble, pages 36664 and 36665 of the Lockout/Tagout Final Rule.

Question 2: Does 1910.169 which covers "Air receivers", apply

to pressure vessels used in conjunction with hydraulic forging presses?

Reply: Section 1910.169 applies to vessels, typically, air receivers, including those in a hydropneumatic forging press, dedicated solely to the storage of air under pressure. Section 1910.169 does not apply to the hydraulic accumulator(s) to which pneumatic pressure is applied or other hydraulic pressure vessels in the hydropneumatic forging press.

If we can be of further assistance, please contact the Office of Safety Compliance Assistance, Mr. Ronald J. Davies, telephone (202)219-8031, extension 110.