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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 14, 1977

Mr. C. Zeilenga
Manager Product Reliability
Verson Allsteel Press Company
[Recipient address omitted]
Dear Mr. Zeilenga:

This is in response to your letter dated November 8, 1976, concerning your request for clarification of 29 CFR 1910.211(d)(8) and (17), in the meaning of concurrent when related to two-hand controls on Mechanical Power Presses.

Concurrent as used in the standards, means the use of both hands and has no relation to simultaneous or any other time element. Within the intent of the standards, there is no requirement that the anti-tiedown feature be provided although tie-downs and bridges are in violation of concurrent use of both hands.

This clarification is not intended to mean that all power press operations with two-hand controls are safe without an anti-tiedown feature, especially those where the two-hand controls are located within arms reach of the point of operations. If this condition is encountered and a serious injury may occur from the hazard, a serious citation may be issued under Section 5(a)(1) of the Occupational Safety and Health Act.

If I may be of any further assistance, please feel free to contact me.

Sincerely,

Donald A. Shay,
Director Office of
Compliance Programming