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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.
October 9, 1998
Mr. Andrew Droitcour
28 Graystone Street
Warwick, Rhode Island 02886-1316
Dear Mr. Droitcour:
This is in response to your letter of July 13, addressed to Mr. John B. Miles, Jr., Former Director of Compliance Programs, with regard to the applicability of the Occupational Safety and Health Administration's (OSHA's) requirements for machine guarding, specifically for automatic screw machines.
Your correspondence indicates that the guarding currently being provided on your automatic screw machines is in accordance with the recommendations of the applicable industry consensus standard (ANSI B11.13-1992, "Single-and Multiple-Spindle Automatic Bar and Chucking Machines..."), and the pertinent manufacturer's requirements for automatic screw machines. However, the applicable OSHA standard, 29 CFR 1910.212, is more stringent, and thus takes precedence. We therefore concur with the Regional interpretation that was issued on May 7th.
The above conclusion was reached as a result of our in-depth review of all of the documents that were provided as attachments to your correspondence. With regard to your training/instruction sheet, please be advised that accidents result from human error as a result of employees that may not follow proper operating procedures. The fact that you are relying on clearing the machine of chips while in operation with a tool does not protect a worker who may take a short-cut and insert a body part to clear the machine.
Thank you for your interest in occupational safety and health. If you have further question, please contact Alcmene Haloftis of my staff at 202-693-1850.
Richard E. Fairfax, Director
Directorate of Compliance Programs