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Single stroke mechanisms on enclosed power presses

Summary An OSHA regional office asked how to classify a missing single stroke mechanism on a full revolution mechanical power press. OSHA said it could be treated as a de minimis violation only when the point of operation was fully guarded, feeding was mechanical, employees had no exposure, and die setters were protected under its instruction. OSHA archives the memo.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1982-04-29
Date issued
April 29, 1982
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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
Topics
Workplace Safety OSHA 1910 Power Presses Machine Guarding Enforcement Policy
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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.

April 29, 1982

MEMORANDUM FOR: CURTIS A. FOSTER
REGIONAL ADMINISTRATOR

THRU: JOHN MILES, DIRECTOR
FIELD COORDINATION

FROM: PATRICK R. TYSON
DIRECTOR, FEDERAL COMPLIANCE AND STATE PROGRAMS

SUBJECT: An Interpretation of 29 CFR 1910.217(b)(3)(i) as requested

Although 29 CFR 1910.217(b)(3)(i) requires the installation of a single stroke mechanism on full revolution mechanical power presses, the absence of the device may be classified as a de minimis violation if all the following circumstances prevail:

  1. The point of operation is completely enclosed with an effective fixed barrier guard, and is in full compliance with 1910.217(c)(2)(i)(b).

  2. Process material is automatically or mechanically fed into the point of operation (Mechanical feeds could utilize semi-automatic fixturing).

  3. There is no actual or potential employee exposure to the point of operation, per FOM Chapter VIII paragraph 3.

  4. Die setters are safeguarded in conformance with OSHA Instruction STD 1-12.24, primarily paragraphs E.3 and E.4.

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