OSHA INSTRUCTION STD 1-12.20 OCTOBER 30,1978

OSHA PROGRAM DIRECTIVE #100-98

TO: REGIONAL ADMINISTRATORS/OSHA

THRU: DONALD E. MACKENZIE Field Coordinator

Subject: 29 CFR 1910.217(b)(3)(i), Mechanical Power Presses Single Stroke Mechanism Requirements

1. Purpose

The purpose of this directive is to provide an interpretation of 29 CFR 1910.217(b)(3)(i) and guidance for field personnel for the requirement of single stroke mechanisms on full revolution type mechanical power presses.

2. Documentation-Affected

This directive supersedes OSHA Field Information Memorandum #77-3 dated February 9, 1977.

3. Background

Complaints and variance applications have been received concerning the requirement for single-stroke mechanisms. This requirement was questioned when full revolution type mechanical power present were used for production type work, automatically fed on continuous operation and the points of operation were protected by a fixed barrier guard. The requirement for the single stroke mechanism was not intended to apply to the preceding type of operation since there is no operator exposure to point of operation hazards when the danger zone is fully enclosed. This exception will be included in a change to the standard, which is presently under review.

4. Action

When encountering full revolution type mechanical power process that are being operated on continuous mode only, feeding and ejection are accomplished by an automatic system, the points of operation are fully enclosed by a fixed barrier guard, and no single stroke mechanism is required, it shall be considered de miminis.

OSHA INSTRUCTION STD 1-12.20 OCTOBER 30, 1978

5. Effective Date

This directive is effective immediately and will remain in effect until rescinded or canceled by standards changes.

Richard P. Wilson Deputy Director, Federal Compliance and State Programs

DISTRIBUTION:

A-1 E-1 B-2 HEW-1 C-1 NIOSH Regional Directors-1 D-4&5 NACOSH-1 Training Institute-4

(Originator: OCCS)