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 8, 1998

Mr. George Henley
HR/us
11 South Elks Street
Terre Haute, IN 47802

Dear Mr. Henley:

This is in response to your August 15, letter requesting interpretation of §1910.217 Mechanical power presses. Please accept our apology for the delay in responding. Your questions and our replies follow.

Question 1:

Is a brake monitor required on a mechanical power press using a partial revolution clutch, when used with two-hand palm button controls, meeting the safe distance requirements and a "NO HANDS IN DIE" operations policy?

Reply:

The answer is no if the No Hands in Die Policy means that the operator never places a hand in the point of operation to feed or remove parts. Paragraph 1910.217(c)(5) requires a brake monitor only when the operator feeds or removes parts by placing one or both hands in the point of operation, and a two-hand control, presence sensing device of Type B gate or movable barrier (on a part revolution clutch) is used for safeguarding.

Question 2:

Is there a specific training period or length of training required for a new or newly assigned employee on a mechanical power press operation?

Reply:

There is no specific training period or length of training required by §1910.217. However, recognizing safe work practices of the general industry, it is reasonable to expect an employer to train an employee and the employee demonstrate proficiency before being assigned to operate a mechanical power press without being under the supervision of a trained person. On-the-job training is acceptable as long as the employee involved is under the direct supervision of a trained person and has received sufficient instruction to enable the trainee to work safely at his or her level of training.

Question 3:

When would the brake system of a mechanical power press manufactured prior to 1971 and equipped with a "band type" brake need updating?

 

  1. When overhauled for the first time.

     

  2. When taken out of service as no longer operable

 

Reply:

 

The fact that a mechanical power press was manufactured prior to August 31, 1971 excuses an employer only from certain requirements for single-stroke, two-hand controls [1910.217(b)(7)(v)(d)] and clutch/brake air-valve controls [1910.217(b)(7)(xi)] (But see paragraph 1910.217(c)(5)). With respect to all other requirements, noncomplying presses must be either removed from service or else brought into compliance without regard for whether an overhaul is otherwise called for.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact the Office of General Industry Compliance Assistance, Mr. Ronald J. Davies or Mr. Walter R. Ziegfried, telephone (202) 219-8031, extension 110 and 105, respectively.

Sincerely,

John B. Miles, Jr., Director
Directorate of Compliance Programs