Guarding package tying machines

July 1, 1985

The Honorable Andy Ireland
House of Representatives
Washington, D.C. 20515
Dear Congressman Ireland:

This is in response to your letter of June 12 to Assistant Secretary Robert A. Rowland, on behalf of Mr. Richard Bunn, regarding the Occupational Safety and Health Administration's (OSHA) requirements on guarding package tying machines.

OSHA does not have a standard that specifically addresses package tying machines. However, there are two general standards that would apply, 29 CFR 1910.212, General requirements for all machines, and 29 CFR 1910.219, Mechanical power transmission apparatus. Copies of those standards are enclosed for Mr. Bunn's reference.

It should be noted that OSHA regulates the employer at a workplace, rather than the manufacturer of the machinery and equipment used at the workplace. It is the responsibility of the employer to ensure compliance with the OSHA standards. Whether a machine is of domestic or foreign manufacture would have no impact on the guarding requirements for the machine; the design of the machine and the resulting exposure to the employee would determine the nature and extent of required guards.

A specific determination regarding compliance with the provisions of the enclosed standards would require a workplace inspection of the equipment and evaluation of the hazards by a knowledgeable individual. We would suggest that your constituent contact our local staff for further guidance at the following address:

U.S. Department of Labor
Occupational Safety and Health Administration
700 Twigg Street
Room 624
Tampa, Florida 33602
Telephone: (813) 228-2821

I hope this information will assist you in your response to Mr. Bunn. If you need further assistance please have a member of your staff contact me or the Special Assistant for Congressional Relations at 523-6027.

Sincerely,
Barry J. White
Director, Directorate of Safety Standards Programs

Enclosures

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