OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

May 15, 1992

MEMORANDUM FOR:     PATRICIA K. CLARK, DIRECTOR
                   DIRECTORATE OF COMPLIANCE PROGRAMS

FROM:               RAYMOND DONNELLY, DIRECTOR
                   OFFICE OF GENERAL INDUSTRY COMPLIANCE ASSISTANCE

SUBJECT:            Flatwork Ironers

This is in response to Acting Assistant Secretary Dottie L. Strunk's upcoming May 20, meeting with representatives of Cooper Industries to discuss potential safety hazards. A search through both the OCIS and our hard copy files resulted in no interpretations or other correspondence on the subject.

OSHA's safety and health requirements for laundry machinery and operations were adopted from ANSI Z8.1-1972 Safety Requirements for Commercial Laundry and Dry Cleaning Equipment and Operations. The safety requirements for flatwork ironers were originally found at 29 CFR 1910.264(c)(3)(ii)(a-d), and consisted of the need for safety bars or other guards across the entire front of the feed or pressure rolls on the various types of ironers to prevent employee contact with the heated surfaces and to prevent the fingers of the employee from being caught between the heated surfaces.

These requirements were revoked by OSHA, as published in the October 24, 1978 Federal Register, because 1910.212(a)(1) and (a)(3)(ii) cover these types of hazards. The BLS Annual Illness and Injury rate for the Laundry Machinery and Operations industry in 1974/75 was 6.2 per 100 full time workers.

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