Spray-booth floor covering and power-press controls

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 9, 1976

Mr. O. V. Simons, Senior
Engineering
American Mutual Insurance Companies
[Recipient address omitted]
RE: Your letter dated August 10, 1976 - 1910.107, Spray Finishing and 1910.217, Mechanical Power Presses

Dear Mr. Simons:

You asked if the use of cardboard panels laid over a concrete floor in a spray booth would be permitted. You stated the cardboard would be replaced daily. Our answer is that this would not be permitted.

As discussed with Mr. Fred Stockmeier of this office, your second question was concerned with the requirements of the mechanical power press standard as it relates to foot controls. During the discussion of your assured's operation, the guarding of the point of operation arose. It appears that guarding may or may not be used according to the particular set of dies being used. Also, the use of foot or hand controls depends upon the dies being used. These variables make it almost impossible to provide an answer to your problem. If foot controls are used, a positive means must be used to keep the employees' hands out of the danger zone. If hand controls are used, they must be placed in accordance with the safety distance requirements. If the employees place their hands between the dies to load or unload on a part revolution clutch press, a brake monitor is required.

Because of the variables involved, we hesitated to give you a firm answer. We are enclosing a brochure describing Triton College's on-site consultation service. Perhaps your assured would consider using this service. Triton's safety engineers, after viewing the operation, could probably provide positive answers to the various questions.

Please contact us if we can be of further service.

Very truly yours,
NICHOLAS DiARCHANGEL
Acting Regional Administrator
for Occupational Safety and Health