OSHA Instruction STD 1.12-27 June 30, 1981 Office of Compliance Programming

Subject: Applicable Standards As They Pertain to Iron Workers and Mechanical Power Presses

A. Purpose. This instruction provides guidelines to aid in the recognition of the difference between iron workers and similarly configured mechanical power presses as they are used in industry. Proper identification will permit the correct application of standards.

B. Scope. This instruction applies OSHA wide.

C. Reference. OSHA Instruction STD 1-12.21, February 2, 1978.

D. Action. OSHA Regional Administrators/Area Directors shall use the guidelines set forth in F of this instruction for the enforcement of 29 CFR 1910.212 and 29 CFR 1910.217, as applicable.

E. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as requested.

3. Ensure that State designees are asked to acknowledge receipt of this 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.

4. 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 and

OSHA Instruction STD 1-12.27 June 30, 1981 Office of Compliance Programming

case file reviews) shall also be used to determine if this change has been implemented in actual performance.

F. Guidelines. For compliance purposes, OSHA field staff will assure that the requirements of 29 CFR 1910.212 and 217, with applicable sections, are applied as interpreted by this instruction.

1. This instruction applies to those combination, multipurpose powered machines that punch, shear, notch, cope, and form metals or other materials, commonly referred to as iron workers, and also applies to certain single-purpose powered machines, noted below.

a. Specific machines to which 29 CFR 1910.212 shall apply include, but are not limited to, the following:

(1) Single-end punches (2) Double-end punches (3) Structural shearing machines (4) Notching machines (5) Coping machines (6) Beam punches (7) Detail punches (8) Spacing punches (9) Combinations of (1) through (8)

b. Machines similar in construction and function to mechanical power presses, but which are identified by the respective machine manufacturers as iron workers, are regulated under 29 CFR 1910.212.

c. Machines whose most distinguishing feature is the multiple work stations at which various operations may be performed singly or simul taneously, including, but not limited to, punching, shearing, notching, coping, and forming, shall be evaluated as an iron worker, and are regulated under 29 CFR 1910.212.

OSHA Instruction STD 1-12.17 June 30, 1981 Office of Compliance Programming

2. Mechanically powered machines that shear, punch, form, or assemble metal or other material by means of tools or dies attached to slides, and identified by their respective manufacturers as mechanical power presses, are regulated under 29 CFR 1910.217.

G. Background. Compliance officers have frequently confused the applicability of standards as they pertain to iron workers and certain configurations of mechanical power presses. In addition, field personnel have incorrectly attempted to enforce provisions of 29 CFR 1910.217 with regard to iron workers. 29 CFR 1910.212 is the appropriate standard to apply to ironworker machines.

1. ANSI B11.5-1975, Safety Requirements for the Construction, Care, and Use of Iron Workers, deals specifically with ironworkers. Although this standard has not been adopted by OSHA under section 6(b), it provides useful guidance in evaluating and correcting ironworker hazards.

2. ANSI B11.5-1975 should be consulted when considering a citation under 1910.212 or when attempting to enforce a citation issued under that standard for exposure to a hazard on an ironworker machine.

Thorne G. Auchter Assistant Secretary

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors