January 9, 1981

Mr. William J. Marshall
Director of Safety and Technical Services
American Metal Stamping Association
27027 Chardon Road
Richmond Heights, Ohio 44143

Dear Mr. Marshall:

This is in response to your correspondence regarding OSHA Instruction STD 1-12.24, dated July 30, 1979.

The OSHA interpretation regarding the safeguarding of mechanical power press diesetters is supported by developed case law established by the Occupational Safety and Health Review Commission. It is the position of the Review Commission that diesetters, as well as any employee performing an operation on a mechanical power press shall be protected from hazardous exposure. Recent case law expressing this position stems from cases such as The Secretary of Labor v. Auto Sun Products Company, OSHRC Docket No. 77-2616. The decision in that case noted that 29 CFR 1910.217 requires point of operation guarding on every operation and that it does not distinguish between set-up and production operations. It was also noted that set-up men are subjected to the identical hazards from the die as are production operators. The decision goes on to explain that 29 CFR 1910.217 allows an employer considerable flexibility in providing either point of operation guards or point of operation safeguarding devices. Much the same conclusion was reached in the case of The Secretary v. General Motors Corporation., Frigidaire Division, Docket No. 76-3693. The OSHA position is therefore consistent with case law developed and established under Occupational Safety and Health Review Commission proceedings.

An interpretation and clarification of the applicability of 29 CFR 1910.217(c)(1)(i) to diesetters was necessary as the result of the case law developments. Whether or not ANSI intended for these provisions to be applicable is not the issue. Rather, it has been determined that the exposures to the die are identical and that various means are available to the employer for providing safeguarding for the diesetter.

The responsibilities of the diesetter to provide and adjust the safeguarding means for the operator are unaffected and remain a requirement.

The statement, "Full revolution mechanical power presses cannot normally be safeguarded with guards during diesetting operations, clearly qualifies our comprehension of the process. It recognizes the necessity to provide safeguarding for the diesetter through other methods such as lock-out or with devices. Yes, the directive literally provides for full revolution power presses which are to be barred with a turnover bar, to be de-energized and the flywheel brought to a stop, and to be locked-out to prevent unintended powering of the press during such operations.

On presses intended to be jogged during those brief periods when point of operation guards have been removed, the directive clearly provides two alternatives for safeguarding the diesetter while jogging. Two-hand jog control is one method. The other is to provide a single jog control protected against accidental actuation and located so that the worker cannot reach into the point of operation while operating the single control. An acceptable single control would be one which allows the press motor to be energized only while the button or switch is manually held in the energized position. Such a single control will allow minimum increment jogging while providing for worker safety.

The use of a separate stop button for the jog mode of operation does not permit safe operations. A two button, start and stop configuration for jog mode operation is a makeshift procedure which does not provide the worker acceptable safeguarding from the point of operation.

Depending upon the wiring configuration desired, a selector switch may or may not be required. However, a selector switch does provide positive administrative control over the procedure in process.

We have been assured by a major U.S. manufacturer of full cycle presses that the modifications necessary to comply with the job circuit requirements are minor and not of a major economic consequence. The economics of such a retrofit or modification is justifiable when related to the normal maintenance costs and to the elimination of continued hazardous exposure provided the diesetter. Studies indicate the metal stamping industry incurs 32% of their employee compensation costs due to power press injuries sustained by their operators and diesetters.

If I may be of further assistance, please call or write.

Sincerely,



John K. Barto
Chief, Division of
Occupational Safety Programming