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.

June 14, 1993

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS
 
FROM: ROGER A. CLARK, DIRECTOR
[DIRECTORATE OF ENFORCEMENT PROGRAMS]
 
SUBJECT: Applicability of the Machine Guarding andLockout/Tagout standards to printing presses.


The attached letter of September 16, 1992 to Mr. John Runyan of the Printing Industries of America, Inc. provides interpretations and clarifications of 29 CFR 1910.147, 1910.212 and 1910.217 as they apply to printing presses only. This letter has been misinterpreted to cover binding and finishing equipment in addition to printing presses. Apparently, this misinterpretation was caused by referencing the use of controls described in ANSI B65.1 for printing press drives and also described in ANSI B65.2 for binding and finishing systems. Similar interpretations and clarifications with respect to binding and finishing systems will be addressed when requested. This request is anticipated in the near future.

Please send a copy of this letter to State Plan States. A copy of this memorandum and the attached letter will be incorporated in OSHA's Computerized Information System (OCIS).

Attachment [-- September 16, 1992 letter to Mr. John Runyan of the Printing Industries of America, Inc.]


May 3, 1993

Mr. Brian J. Bobal
Director of Safety and Health
Graphic Communication International Union
1900 L Street N.W.
Washington, D.C. 20036

Dear Mr. Bobal:

This is in response to your March 23 letter requesting clarification on the scope of workplace coverage intended by our September 16, 1992 letter to Mr. John Runyan of the Printing Industries of America, Inc. In that letter, OSHA explained its interpretation of the applicability of the lockout-tagout standard, to printing presses. (Copy enclosed)

As clearly indicated in the first paragraph, the aforementioned letter interprets and clarifies 29 CFR 1910.147, 1910.212 and 1910.219 as those OSHA standards apply to printing presses. Apparently, confusion was caused by the reference (in our letter to Mr. Runyan) to OSHA and ANSI standards relating to the design of printing presses, and of binding and finishing systems and their respective control equipment (ANSI B65.1 and B65.2) on pages 1 and 3 of the enclosed letter.

We will provide our field office with copies of this letter to inform them of this potential problem. Thank you for your interest in occupational safety and health. If we can be of further assistance, please contact us.

Sincerely,

Raymond E. Donnelly, Director
[Office of General Industry Enforcement]

[Corrected 4/27/2004]