OSHA INSTRUCTION STD 1-12.6
OCTOBER 30, 1978
OSHA PROGRAM DIRECTIVE #100-29
TO: ASSISTANT REGIONAL DIRECTORS/OSH
Subject: 29 CFR 1910.218 Forging Machines
1. Purpose
To clarify appropriate enforcement of 29 CFR 1910.218.
2. Directives Affected
Cancels FIM #74-82 dated October 15, 1974.
3. Background
Several situations have arisen where alleged violations of hot forging
operations have been cited under 29 CFR 1910.212 and Section 5(a)(1)
of the Act. The citations were inappropriate in that there were
specific standards to cover the operations in 29 CFR 1910.218.
4. Clarification
Employees working with machines used in the forming of hot metal
including hot trimming Presses, forging hammers, hot forging presses,
upsetters, hot bending and hot metal presses, etc., use tongs of a
sufficient length to avoid heat as well as the ram. Therefore the
standards contained in 29 CFR 1910.218 shall be applicable.
5. Action
All citations which have been issued for a violation of 29 CFR
1910.212, Point of Operation Guarding, or 5(a)(1) of the Act involving
the above situations shall be withdrawn. It is further advised that
all penalties which have been collected as a result of such citations
be returned to the employer involved.
2
OSHA INSTRUCTION STD 1-12.6
OCTOBER 30, 1978
A citation for violations of 29 CFR 1910.212 or 5(a)(1) would be
appropriate only when a condition exists that could be recognized as a
hazard and conditions are other than normal forging machine operations
covered by 29 CFR 1910.218.
Barry J. White
Associate Assistant Secretary
for Regional Programs
DISTRIBUTION:
NATIONAL OFFICE FIELD
A/Sec. (3) Assistant Regional Director/OSH (3)
Dep. Asst./Sec. (2) AARD Technical (2)
Spec. Asst. (1) AARD Training (2)
Associate Asst./Sec. (3) AARD Federal/State (2)
Office Directors (3) Area/District Offices (3)
Division Chiefs (1) Training Institute (10)
SOL (35) Professional Staff (1 ea.)
BLS (1) Designated State Agencies (1)
Review Commission (6) NIOSH Regional Program Directors (1)
HEW (1) SOL Regional Attorneys (1)
OGO Professional Staff (50) Review Commission Regional
OS Professional Staff (50) Offices (1)
NACOSH Committee (1)
Regional Directors (11)