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Pneumatic drop hammers in hot and cold forging

Summary A state safety official asked whether the safety-cylinder-head rule covered a pneumatic drop hammer. OSHA said the cited provision applied to pneumatic drop hammers used in hot forging, while cold-forging hammers fell under other applicable standards and the general duty clause. The incoming requester letter is reproduced on OSHA’s page.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-06-05
Date issued
June 5, 1979
Status
Active
Status last verified October 10, 2026

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

June 5, 1979

Mr. Michael Rodgers, Director
OSHA Voluntary Compliance and Training
Commonwealth of Virginia
Department of Labor and Industry
[Recipient address omitted]
Dear Mr. Rodgers:

This is in response to your inquiry addressed to Mr. John A. Proctor concerning the application of 29 CFR 1910.218(e)(1)(i) to the type of hammer referenced in your attached brochure.

As you were informed in a telephone conversation with Mr. Simms, a member of my staff, the use of the forging machines must be determined before the standard can be properly enforced. 29 CFR 1910.218(e)(1)(i) shall be enforced for pneumatic drop hammers used in hot forging operations. However, pneumatic drop hammers used for cold forging operations are not covered by the standard, but are covered by other applicable standards and section 5(a)(1) of the Act.

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

Sincerely,
Grover C. Wrenn Director
Federal Compliance
and State Programs

[Requester letter reproduced on OSHA page; omitted here.]

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