OSHA Hazard Information Bulletins
December 8, 1989
| MEMORANDUM FOR: | REGIONAL ADMINISTRATORS |
| |
| THRU: | LEO CAREY
Director
Office of Field Programs |
| |
| FROM: | BARRY WHITE
Director
Directorate of Technical Support |
| |
| SUBJECT: | Safety Hazard Information Bulletin on Platen Presses |
The Directorate of Technical Support is charged with the responsibility of
evaluating and disseminating technical information to support safety and
health professionals. Information supplied covers a wide range of subjects
through a number of different delivery mechanisms including on-line services,
Technical Bulletins, memoranda, manuals and Instructions. The following
information is presented under the Directorate of Technical Support's Hazard
Information Bulletin (HIB) Series. Bulletins are published as needed to
provide relevant information regarding unrecognized or misunderstood health
hazards, inadequacies of materials, devices, techniques, and engineering
controls. HIB's are initiated based on the appearance of relevant
information in studies and reports, through concerns expressed by safety and
health professionals, employers and the public. Information is compiled
based on a thorough evaluation of available facts, literature and in
coordination with appropriate parties. The Directorate of Technical Support
sees the HIB series as a vehicle for the dissemination of technical
information to OSHA personnel. Inevitably the availability of new information
will affect compliance actions. Specific guidance on compliance policy should
be sought through appropriate channels.
The Boston Regional Office has brought to our attention information
regarding the engineering feasibility of point of operation guarding of
pre-1960 Kluge platen presses. These presses are used nationwide in the
printing industry as well as in vocational education. The manufacturer,
Brandtjen & Kluge, Inc., indicates that there is no practical way to bring
pre-1960 Kluge presses within OSHA guarding standards.
Reference to testimony given by Mr. Henry Brandtjen, Jr., President,
Brandtjen & Kluge, Inc., in a lawsuit initiated by Brandtjen & Kluge against
Mr. Dale Prudhomme of the Joe Purdhomme Company, Dallas, Texas, alleging
trademark infringement based on Mr. Prudhomme's repair and rebuilding of
Kluge presses, has been submitted in a letter to our office by Mr. John L.
Sigalos, attorney for Mr. Prudhomme:
"We would submit to you that the pre-1960 machines are safe, as Mr.
Brandtjen has testified under oath, and that the issue is whether the users
are indeed properly instructing their personnel how to use the machine. Use
of the machine in automatic feeding mode, as sold by our client, provides
adequate point-of-operation safety (OSHA Instruction STD 1-12.22). Further,
our client specifically warns against hand feeding the presses in the
operation and maintenance booklet supplied to its customers.
. . . Moreover, our client places prominent legends on the presses
at points of operation warning against hand feeding.
. . . The letters sent out by Brandtjen & Kluge, Inc., are in our
client's opinion a "false alarm," not based on fact, whose true purpose is to
increase sales of new Brandtjen & Kluge presses."
The guarding of platen presses is addressed in OSHA Instruction STD 1-12.22.
The directive provides guidance in applying point of operation guarding for
such machines when using the face down printing method.
Please distribute this bulletin to all Area Offices, State Plan States and
Consultation Projects.
|
Back to Top
Printing Instructions