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Two-hand molding-press controls and accidental operation

Summary A plastics company asked whether two-hand molding-press buttons needed surrounding guards. OSHA said the controls had to be protected against unintended operation and that their location or height could supply that protection; it found the described controls compliant. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-04-23
Date issued
April 23, 1975
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 23, 1975

Mr. Neil C. Woodworth
Hooker Chemicals and Plastics Corporation
Durez Division
[Recipient address omitted]
Dear Mr. Woodworth:

This is in response to your letter dated January 20, 1975, and several telephone conversations with a member of our staff, concerning whether buttons on the two-handed controls of your molding presses required a surrounding guard.

Section 1910.217(b)(6)(i) and (b)(7)(v)(a) of the General Standards require that they be "protected against unintentional operation". This protection may be in the form of the guarding as you describe, or the location or height, which would provide a natural protection.

Based on the information from the above telephone conversations and the photographs that you submitted, it has been determined that the location of these controls meet the requirements within the meaning of these standards.

Thank you for your continuing interest in safety and if I may be of further assistance, please feel free to contact me.

Sincerely,
John K. Barto,
Chief Division of
Occupational Safety Programming

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