OSHA INSTRUCTION STD 1-12.6 OCTOBER 30, 1978

OSHA PROGRAM DIRECTIVE #100-29

TO: ASSISTANT REGIONAL DIRECTORS/OSH

Subject: 29 CFR 1910.218 Forging Machines

1. Purpose

To clarify appropriate enforcement of 29 CFR 1910.218.

2. Directives Affected

Cancels FIM #74-82 dated October 15, 1974.

3. Background

Several situations have arisen where alleged violations of hot forging operations have been cited under 29 CFR 1910.212 and Section 5(a)(1) of the Act. The citations were inappropriate in that there were specific standards to cover the operations in 29 CFR 1910.218.

4. Clarification

Employees working with machines used in the forming of hot metal including hot trimming Presses, forging hammers, hot forging presses, upsetters, hot bending and hot metal presses, etc., use tongs of a sufficient length to avoid heat as well as the ram. Therefore the standards contained in 29 CFR 1910.218 shall be applicable.

5. Action

All citations which have been issued for a violation of 29 CFR 1910.212, Point of Operation Guarding, or 5(a)(1) of the Act involving the above situations shall be withdrawn. It is further advised that all penalties which have been collected as a result of such citations be returned to the employer involved.

OSHA INSTRUCTION STD 1-12.6 OCTOBER 30, 1978

A citation for violations of 29 CFR 1910.212 or 5(a)(1) would be appropriate only when a condition exists that could be recognized as a hazard and conditions are other than normal forging machine operations covered by 29 CFR 1910.218.

Barry J. White Associate Assistant Secretary for Regional Programs

DISTRIBUTION:

NATIONAL OFFICE FIELD

A/Sec. (3) Assistant Regional Director/OSH (3) Dep. Asst./Sec. (2) AARD Technical (2) Spec. Asst. (1) AARD Training (2) Associate Asst./Sec. (3) AARD Federal/State (2) Office Directors (3) Area/District Offices (3) Division Chiefs (1) Training Institute (10) SOL (35) Professional Staff (1 ea.) BLS (1) Designated State Agencies (1) Review Commission (6) NIOSH Regional Program Directors (1) HEW (1) SOL Regional Attorneys (1) OGO Professional Staff (50) Review Commission Regional OS Professional Staff (50) Offices (1) NACOSH Committee (1) Regional Directors (11)