|Directive Number: STD 01-12-024 (formerly STD 1.12.24)
||Effective Date: JULY 30, 1979|
Office of Compliance Programming
|Subject: Clarification and Interpretation of 29 CFR 1910. 217, Mechanical Power Presses, as Applied to the Safeguarding Requirements for Diesetters|
|Note: This 1979 OSHA Instruction was published prior to the promulgation of the Control of hazardous energy (lockout/tagout) standard. The April 22, 2005 letter to Mr. William H. Kincaid of the Lockton Companies of St. Louis provides additional guidance on energy control requirements and the associated hazards related to hydraulic and mechanical power press servicing and maintenance activities.|
Grover C. Wrenn Director, Federal Compliance and State Programs
- Purpose. This instruction provides guidance in applying
point-of-operation guarding requirements on mechanical power presses during
diesetting operations. Also, it provides for the application of consensus
standards and identifies topographical errors in 29 CFR 1910.
- Scope. This instruction applies OSHA-wide.
- Action. OSHA Regional Administrators/Area Directors shall use the
guidelines set forth in paragraph F. of this instruction for enforcement of
the referenced standard.
- Federal Program Change. This instruction describes a Federal program
change which affects State programs. Each Regional Administrator shall:
- Ensure that this change is forwarded to each State designee.
- Explain the technical content of the change to the State
designees as requested.
- Ensure that State designees are asked to acknowledge receipt of
the Federal Program change in writing, within 30 days of notification, to the
Regional Administrator. The acknowledgment should include a description
either of the State's plan to implement the change or of the reasons why the
change should not apply to that State.
- Review policies, instructions and guidelines issued by the
State to determine that this change has been communicated to State program
personnel. Routine monitoring activities (accompanied inspections, spot check
visits and case file reviews) shall also be used to determine if this change
has been implemented in actual performance.
- Background. 29 CFR 1910.217(c)(1)(i) requires protection of employees
through the use of point-of-operation guards or devices (as defined in 29 CFR
1910.211(d)(11) and (32)) on every operation performed on a mechanical power
press. Diesetters working on mechanical power presses are covered by the
provisions of 29 CFR 1910.217(c).
- 29 CFR 1910.217(d) provides specifically for the protection of
diesetters. 29 CFR 1910.217(d)(9) (i) was intended to clarify that the
provisions of 29 CFR 1910.217(c) apply to diesetters concerning
point-of-operation guarding. When 29 CFR 1910.217(d)(9)(i) was adopted, it
erroneously referred to paragraph (b) of 1910.217 rather than to paragraph
(c). The typographical error occurred during a reorganization of the
provisions of the ANSI B11.1-1971 standard when it was incorporated into 29
CFR 1910 as Section .217. Additional typographical errors
- Erroneous references to paragraph (b) rather than to
paragraph (c) by 29 CFR 1910.217(d) (3) and (d)(5).
- 29 CFR 1910.217(b)(8)(iv) erroneously refers to "a nominal
240-volt d.c. supply obtained from a transformer" where it should have read
- Mechanical power presses equipped with part revolution clutches
comply with point-of-operation safeguarding for diesetters when an inch mode
is installed as specified in 29 CFR 1910.217(b)(7)(iv). Use of the inch mode
in accordance with 1910.217(b)(7)(iv) constitutes use of a "device" within
the meaning of 1910.217(d)(11).
- Full revolution mechanical power presses cannot normally be
safeguarded with guards during die-setting operations. However, in instances
when guards are not applicable and for presses provided with barring holes in
the flywheel, the diesetter is protected if:
- The power press is de-energized and the flywheel is brought
to rest; and
- The prime mover power to the power press is locked-out; and
- The slide is moved by manually turning the crankshaft with
the aid of a turnover bar (a lever) inserted through the barring hole in the
- On some full revolution mechanical power presses, primarily
those over 60 tons in size, the slide cannot be moved manually during
diesetting. Safeguarding is provided if they are equipped with a jog mode of
- The flywheel is brought to rest and the clutch is engaged
before the drive motor is jogged, and
- The jog control requires two-hand operation, or
- The jog control is a single control protected against
accidental actuation and so located that the worker cannot reach into the
point-of-operation while operating the single control.
- For full revolution mechanical power presses, safeguarding of
the diesetter, as set forth in E.3., and E.4. constitutes a "device" as
defined in 29 CFR 1910.211(d)(11).
- ANSI B11.1-1971, Section 2.51 regarding turnover bars states:
Two methods of insuring the removal of the turnover bar from the barring hole
have been found acceptable. They are (1) use of spring action on the end of
the bar, and (2) use of storage pockets for the bar, incorporating an
- Guidelines. For compliance purposes, OSHA field staff will assure that
the requirements of 29 CFR 1910.217 and applicable sections are interpreted
in the following manner:
- As the result of the errors noted in paragraph E.1., when
diesetters are operating a mechanical power press, such as running test and
production parts, diesetting or trouble shooting, they shall be protected by point-of-operation guards or devices. Failure to
provide such safeguards shall constitute a violation of 29 CFR
- When diesetters operate a mechanical power press, equipped with
a part revolution clutch, in the inch mode where such device is not installed
per 29 CFR 1910.217(b)(7)(iv), a violation exists and a citation shall be
issued if no alternative safe guard is provided
- As the result of the errors noted in paragraph E.1., when a
diesetter operates a full cycle mechanical power press without
point-of-operation guards or devices such as those described in paragraphs
E,3. and E.4., the employer shall be for a violation of 29 CFR
- On mechanical power presses equipped with part revolution
clutches, turnover bar operations shall comply with 29 CFR
1910.217(b)(7)(xv). (See also paragraph E.6.)
- Regarding 29 CFR 1910.217(b)(8)(iv), where employee exposure is
established, 5(a)(1) citations shall be issued with reference to ANSI
B11.1-1971, section 3.6.4., when mechanical power press control circuits and
solennoid valve coils are not powered by a nominal 120-volt a.c. or less as
stipulated by ANSI B11.1-1971.
DISTRIBUTION: National, Regional and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors