29 CFR 1910.217(h)

29cfr1910.217(h)(2009).pdf

Presence Sensing Device Initiation (PSDI) (29 CFR 1910.217(h))

29 CFR 1910.217(h)

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

TABLE O–10—Continued
[In inches]
Distance of opening from point of operation hazard
51⁄2 to 61⁄2 ............................................................
61⁄2 to 71⁄2 ............................................................
71⁄2 to 121⁄2 ..........................................................
121⁄2 to 151⁄2 ........................................................
151⁄2 to 171⁄2 ........................................................
171⁄2 to 311⁄2 ........................................................

Maximum
width of
opening
⁄
7⁄8
11⁄4
11⁄2
17⁄8
21⁄8
34

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This table shows the distances that guards
shall be positioned from the danger line in
accordance with the required openings.

(g) Reports of injuries to employees operating mechanical power presses. (1) The
employer shall, within 30 days of the
occurrence, report to either the Director of the Directorate of Safety Standards Programs, OSHA, U.S. Department of Labor, Washington, D.C. 20210,
or the State agency administering a
plan approved by the Assistant Secretary of Labor for Occupational Safety and Health, all point of operation
injuries to operators or other employees. The following information shall be
included in the report:
(i) Employer’s name, address and location of the workplace (establishment).
(ii) Employee’s name, injury sustained, and the task being performed
(operation, set-up, maintenance, or
other).
(iii) Type of clutch used on the press
(full revolution, part revolution, or direct drive).
(iv) Type of safeguard(s) being used
(two hand control, two hand trip, pullouts, sweeps, or other). If the safeguard
is not described in this section, give a
complete description.
(v) Cause of the accident (repeat of
press, safeguard failure, removing
stuck part or scrap, no safeguard provided, no safeguard in use, or other).
(vi) Type of feeding (manual with
hands in dies or with hands out of dies,
semiautomatic, automatic, or other).
(vii) Means used to actuate press
stroke (foot trip, foot control, hand
trip, hand control, or other).
(viii) Number of operators required
for the operation and the number of operators provided with controls and
safeguards.
(h) Presence sensing device initiation
(PSDI)—(1) General. (i) The require-

ments of paragraph (h) shall apply to
all part revolution mechanical power
presses used in the PSDI mode of operation.
(ii) The relevant requirements of
paragraphs (a) through (g) of this section also shall apply to all presses used
in the PSDI mode of operation, whether or not cross referenced in this paragraph (h). Such cross-referencing of
specific requirements from paragraphs
(a) through (g) of this section is intended only to enhance convenience
and understanding in relating to the
new provisions to the existing standard, and is not to be construed as limiting the applicability of other provisions in paragraphs (a) through (g) of
this section.
(iii) Full revolution mechanical
power presses shall not be used in the
PSDI mode of operation.
(iv) Mechanical power presses with a
configuration which would allow a person to enter, pass through, and become
clear of the sensing field into the hazardous portion of the press shall not be
used in the PSDI mode of operation.
(v) The PSDI mode of operation shall
be used only for normal production operations. Die-setting and maintenance
procedures shall comply with paragraphs (a) through (g) of this section,
and shall not be done in the PSDI
mode.
(2) Brake and clutch requirements. (i)
Presses with flexible steel band brakes
or with mechanical linkage actuated
brakes or clutches shall not be used in
the PSDI mode.
(ii) Brake systems on presses used in
the PSDI mode shall have sufficient
torque so that each average value of
stopping times (Ts) for stops initiated
at approximately 45 degrees, 60 degrees,
and 90 degrees, respectively, of crankshaft angular position, shall not be
more than 125 percent of the average
value of the stopping time at the top
crankshaft position. Compliance with
this requirement shall be determined
by using the heaviest upper die to be
used on the press, and operating at the
fastest press speed if there is speed selection.
(iii) Where brake engagement and
clutch release is effected by spring action, such spring(s) shall operate in
compression on a rod or within a hole

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Occupational Safety and Health Admin., Labor
or tube, and shall be of non-interleaving design.
(3) Pneumatic systems. (i) Air valve
and air pressure supply/control.
(A) The requirements of paragraphs
(b)(7)(xiii), (b)(7)(xiv), (b)(10), (b)(12)
and (c)(5)(iii) of this section apply to
the pneumatic systems of machines
used in the PSDI mode.
(B) The air supply for pneumatic
clutch/brake control valves shall incorporate a filter, an air regulator, and,
when necessary for proper operation, a
lubricator.
(C) The air pressure supply for
clutch/brake valves on machines used
in the PSDI mode shall be regulated to
pressures less than or equal to the air
pressure used when making the stop
time measurements required by paragraph (h)(2)(ii) of this section.
(ii) Air counterbalance systems.
(A) Where presses that have slide
counterbalance systems are used in the
PSDI mode, the counterbalance system
shall also meet the requirements of
paragraph (b)(9) of this section.
(B) Counterbalances shall be adjusted
in accordance with the press manufacturer’s recommendations to assure correct counterbalancing of the slide attachment (upper die) weight for all operations performed on presses used in
the PSDI mode. The adjustments shall
be made before performing the stopping time measurements required by
paragraphs (h)(2)(ii), (h)(5)(iii), and
(h)(9)(v) of this section.
(4) Flywheels and bearings. Presses
whose designs incorporate flywheels
running on journals on the crankshaft
or back shaft, or bull gears running on
journals mounted on the crankshaft,
shall be inspected, lubricated, and
maintained as provided in paragraph
(h)(10) of this section to reduce the possibility of unintended and uncontrolled
press strokes caused by bearing seizure.
(5) Brake monitoring. (i) Presses operated in the PSDI mode shall be
equipped with a brake monitor that
meets the requirements of paragraphs
(b)(13) and (b)(14) of this section. In addition, the brake monitor shall be adjusted during installation certification
to prevent successive stroking of the
press if increases in stopping time
cause an increase in the safety distance

§ 1910.217

above that required by paragraph
(h)(9)(v) of this section.
(ii) Once the PSDI safety system has
been certified/validated, adjustment of
the brake monitor shall not be done
without prior approval of the validation organization for both the brake
monitor adjustment and the corresponding adjustment of the safety
distance. The validation organization
shall in its installation validation,
state that in what circumstances, if
any, the employer has advance approval for adjustment, when prior oral
approval is appropriate and when prior
approval must be in writing. The adjustment shall be done under the supervision of an authorized person whose
qualifications include knowledge of
safety distance requirements and experience with the brake system and its
adjustment. When brake wear or other
factors extend press stopping time beyond the limit permitted by the brake
monitor, adjustment, repair, or maintenance shall be performed on the
brake or other press system element
that extends the stopping time.
(iii) The brake monitor setting shall
allow an increase of no more than 10
percent of the longest stopping time
for the press, or 10 milliseconds, whichever is longer, measured at the top of
the stroke.
(6) Cycle control and control systems. (i)
The control system on presses used in
the PSDI mode shall meet the applicable requirements of paragraphs (b)(7),
(b)(8), (b)(13), and (c)(5) of this section.
(ii) The control system shall incorporate a means of dynamically monitoring for decoupling of the rotary position indicating mechanism drive
from the crankshaft. This monitor
shall stop slide motion and prevent
successive press strokes if decoupling
occurs, or if the monitor itself fails.
(iii) The mode selection means of
paragraph (b)(7)(iii) of this section
shall have at least one position for selection of the PSDI mode. Where more
than one interruption of the light sensing field is used in the initiation of a
stroke, either the mode selection
means must have one position for each
function, or a separate selection means
shall be provided which becomes operable when the PSDI mode is selected.

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

Selection of PSDI mode and the number of interruptions/withdrawals of the
light sensing field required to initiate
a press cycle shall be by means capable
of supervision by the employer.
(iv) A PSDI set-up/reset means shall
be provided which requires an overt action by the operator, in addition to
PSDI mode selection, before operation
of the press by means of PSDI can be
started.
(v) An indicator visible to the operator and readily seen by the employer
shall be provided which shall clearly
indicate that the system is set-up for
cycling in the PSDI mode.
(vi) The control system shall incorporate a timer to deactivate PSDI
when the press does not stroke within
the period of time set by the timer.
The timer shall be manually adjustable, to a maximum time of 30 seconds.
For any timer setting greater than 15
seconds, the adjustment shall be made
by the use of a special tool available
only to authorized persons. Following a
deactivation of PSDI by the timer, the
system shall make it necessary to reset
the set-up/reset means in order to reactivate the PSDI mode.
(vii) Reactivation of PSDI operation
following deactivation of the PSDI
mode from any other cause, such as activation of the red color stop control
required by paragraph (b)(7)(ii) of this
section, interruption of the presence
sensing field, opening of an interlock,
or reselection of the number of sensing
field
interruptions/withdrawals
required to cycle the press, shall require
resetting of the set-up/reset means.
(viii) The control system shall incorporate an automatic means to prevent
initiation or continued operation in
the PSDI mode unless the press drive
motor is energized in the forward direction of crankshaft rotation.
(ix) The control design shall preclude
any movement of the slide caused by
operation of power on, power off, or selector switches, or from checks for
proper operations as required by paragraph (h)(6)(xiv) of this section.
(x) All components and subsystems of
the control system shall be designed to
operate together to provide total control system compliance with the requirements of this section.

(xi) Where there is more than one operator of a press used for PSDI, each
operator shall be protected by a separate, independently functioning, presence sensing device. The control system shall require that each sensing
field be interrupted the selected number of times prior to initiating a
stroke. Further, each operator shall be
provided with a set-up/reset means that
meets the requirements of paragraph
(h)(6) of this section, and which must
be actuated to initiate operation of the
press in the PSDI mode.
(xii) [Reserved]
(xiii) The Control system shall incorporate interlocks for supplemental
guards, if used, which will prevent
stroke initiation or will stop a stroke
in progress if any supplemental guard
fails or is deactivated.
(xiv) The control system shall perform checks for proper operation of all
cycle control logic element switches
and contacts at least once each cycle.
Control elements shall be checked for
correct status after power ‘‘on’’ and before the initial PSDI stroke.
(xv) The control system shall have
provisions for an ‘‘inch’’ operating
means meeting the requirements of
paragraph (b)(7)(iv) of this section. Diesetting shall not be done in the PSDI
mode. Production shall not be done in
the ‘‘inch’’ mode.
(xvi) The control system shall permit
only a single stroke per initiation command.
(xvii) Controls with internally stored
programs (e.g., mechanical, electro-mechanical, or electronic) shall meet the
requirements of paragraph (b)(13) of
this section, and shall default to a predetermined safe condition in the event
of any single failure within the system.
Programmable controllers which meet
the requirements for controls with internally stored programs stated above
shall be permitted only if all logic elements affecting the safety system and
point of operation safety are internally
stored and protected in such a manner
that they cannot be altered or manipulated by the user to an unsafe condition.
(7) Environmental requirements. Control components shall be selected, constructed, and connected together in
such a way as to withstand expected

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Occupational Safety and Health Admin., Labor
operational
and
environmental
stresses, at least including those outlined in appendix A. Such stresses shall
not so affect the control system as to
cause unsafe operation.
(8) Safety system. (i) Mechanical
power presses used in the PSDI mode
shall be operated under the control of a
safety system which, in addition to
meeting the applicable requirements of
paragraphs (b)(13) and (c)(5) and other
applicable provisions of this section,
shall function such that a single failure
or single operating error shall not
cause injury to personnel from point of
operation hazards.
(ii) The safety system shall be designed, constructed, and arranged as an
integral total system, including all elements of the press, the controls, the
safeguarding and any required supplemental safeguarding, and their interfaces with the operator and that part
of the environment which has effect on
the protection against point of operation hazards.
(9) Safeguarding the point of operation.
(i) The point of operation of presses operated in the PSDI mode shall be safeguarded in accordance with the requirements of paragraph (c) of this section, except that the safety distance
requirements of paragraph (h)(9)(v) of
this section shall be used for PSDI operation.
(ii)(A) PSDI shall be implemented
only by use of light curtain (photoelectric) presence sensing devices
which meet the requirements of paragraph (c)(3)(iii)(c) of this section unless
the requirements of the following paragraph have been met.
(B) Alternatives to photo-electric
light curtains may be used for PSDI
when the employer can demonstrate,
through tests and analysis by the employer or the manufacturer, that the
alternative is as safe as the photo-electric light curtain, that the alternative
meets the conditions of this section,
has the same long term reliability as
light curtains and can be integrated
into the entire safety system as provided for in this section. Prior to use,
both the employer and manufacturer
must certify that these requirements
and all the other applicable requirements of this section are met and these
certifications must be validated by an

§ 1910.217

OSHA-recognized third-party validation organization to meet these additional requirements and all the other
applicable requirements of paragraphs
(a) through (h) and appendix A of this
section. Three months prior to the operation of any alternative system, the
employer must notify the OSHA Directorate of Safety Standards Programs of
the name of the system to be installed,
the manufacturer and the OSHA-recognized third-party validation organization immediately. Upon request, the
employer must make available to that
office all tests and analyses for OSHA
review.
(iii) Individual sensing fields of presence sensing devices used to initiate
strokes in the PSDI mode shall cover
only one side of the press.
(iv) Light curtains used for PSDI operation shall have minimum object
sensitivity not to exceed one and onefourth inches (31.75 mm). Where light
curtain object sensitivity is user-adjustable, either discretely or continuously, design features shall limit the
minimum object sensitivity adjustment not to exceed one and one-fourth
inches (31.75 mm). Blanking of the
sensing field is not permitted.
(v) The safety distance (Ds) from the
sensing field of the presence sensing
device to the point of operation shall
be greater than or equal to the distance determined by the formula:
Ds = Hs×(Ts+Tp+Tr+2Tm)+Dp
Where:
Ds = Minimum safety distance.
Hs = Hand speed constant of 63 inches per
second (1.6 m/s).
Ts = Longest press stopping time, in seconds,
computed by taking averages of multiple
measurements at each of three positions
(45 degrees, 60 degrees, and 90 degrees) of
crankshaft angular position; the longest of
the three averages is the stopping time to
use. (Ts is defined as the sum of the kinetic
energy dissipation time plus the pneumatic/magnetic/hydraulic reaction time of
the clutch/brake operating mechanism(s).)
Tp = Longest presence sensing device response time, in seconds.
Tr = Longest response time, in seconds, of all
interposing control elements between the
presence sensing device and the clutch/
brake operating mechanism(s).
Tm = Increase in the press stopping time at
the top of the stroke, in seconds, allowed
by the brake monitor for brake wear. The
time increase allowed shall be limited to

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)
the presence sensing field by fingers or
hand before detection occurs. The penetration depth factor shall be determined from
Graph h–1 using the minimum object sensitivity size.

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no more than 10 percent of the longest
press stopping time measured at the top of
the stroke, or 10 milliseconds, whichever is
longer.
Dp = Penetration depth factor, required to
provide for possible penetration through

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(vi) The presence sensing device location shall either be set at each tool
change and set-up to provide at least
the minimum safety distance, or fixed

§ 1910.217

in location to provide a safety distance
greater than or equal to the minimum
safety distance for all tooling set-ups
which are to be used on that press.

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

(vii) Where presence sensing device
location is adjustable, adjustment shall
require the use of a special tool available only to authorized persons.
(viii)
Supplemental
safeguarding
shall be used to protect all areas of access to the point of operation which are
unprotected by the PSDI presence sensing device. Such supplemental safeguarding shall consist of either additional light curtain (photo-electric)
presence sensing devices or other types
of guards which meet the requirements
of paragraphs (c) and (h) of this section.
(A) Presence sensing devices used as
supplemental safeguarding shall not
initiate a press stroke, and shall conform to the requirements of paragraph
(c)(3)(iii) and other applicable provisions of this section, except that the
safety distance shall comply with paragraph (h)(9)(v) of this section.
(B) Guards used as supplemental safeguarding shall conform to the design,
construction and application requirements of paragraph (c)(2) of this section, and shall be interlocked with the
press control to prevent press PSDI operation if the guard fails, is removed,
or is out of position.
(ix) Barriers shall be fixed to the
press frame or bolster to prevent personnel
from
passing
completely
through the sensing field, where safety
distance or press configuration is such
that personnel could pass through the
PSDI presence sensing field and assume
a position where the point of operation
could be accessed without detection by
the PSDI presence sensing device. As
an alternative, supplemental presence
sensing devices used only in the safeguard mode may be provided. If used,
these devices shall be located so as to
detect all operator locations and positions not detected by the PSDI sensing
field, and shall prevent stroking or
stop a stroke in process when any supplemental sensing field(s) are interrupted.
(x) Hand tools. Where tools are used
for feeding, removal of scrap, lubrication of parts, or removal of parts that
stick on the die in PSDI operations:
(A) The minimum diameter of the
tool handle extension shall be greater
than the minimum object sensitivity of

the presence sensing device(s) used to
initiate press strokes; or
(B) The length of the hand tool shall
be such as to ensure that the operator’s
hand will be detected for any safety
distance required by the press set-ups.
(10) Inspection and maintenance. (i)
Any press equipped with presence sensing devices for use in PSDI, or for supplemental safeguarding on presses used
in the PSDI mode, shall be equipped
with a test rod of diameter specified by
the presence sensing device manufacturer to represent the minimum object
sensitivity of the sensing field. Instructions for use of the test rod shall be
noted on a label affixed to the presence
sensing device.
(ii) The following checks shall be
made at the beginning of each shift and
whenever a die change is made.
(A) A check shall be performed using
the test rod according to the presence
sensing device manufacturer’s instructions to determine that the presence
sensing device used for PSDI is operational.
(B) The safety distance shall be
checked for compliance with (h)(9)(v) of
this section.
(C) A check shall be made to determine that all supplemental safeguarding is in place. Where presence
sensing devices are used for supplemental safeguarding, a check for proper operation shall be performed using
the test rod according to the presence
sensing device manufacturer’s instructions.
(D) A check shall be made to assure
that the barriers and/or supplemental
presence sensing devices required by
paragraph (h)(9)(ix) of this section are
operating properly.
(E) A system or visual check shall be
made to verify correct counterbalance
adjustment for die weight according to
the press manufacturer’s instructions,
when a press is equipped with a slide
counterbalance system.
(iii) When presses used in the PSDI
mode have flywheel or bullgear running on crankshaft mounted journals
and bearings, or a flywheel mounted on
back shaft journals and bearings, periodic inspections following the press
manufacturer’s recommendations shall
be made to ascertain that bearings are

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Occupational Safety and Health Admin., Labor
in good working order, and that automatic lubrication systems for these
bearings (if automatic lubrication is
provided) are supplying proper lubrication. On presses with provision for
manual lubrication of flywheel or
bullgear bearings, lubrication shall be
provided according to the press manufacturer’s recommendations.
(iv) Periodic inspections of clutch
and brake mechanisms shall be performed to assure they are in proper operating condition. The press manufacturer’s recommendations shall be followed.
(v) When any check of the press, including those performed in accordance
with the requirements of paragraphs
(h)(10)(ii), (iii) or (iv) of this section,
reveals a condition of noncompliance,
improper adjustment, or failure, the
press shall not be operated until the
condition has been corrected by adjustment, replacement, or repair.
(vi) It shall be the responsibility of
the employer to ensure the competence
of personnel caring for, inspecting, and
maintaining power presses equipped for
PSDI operation, through initial and
periodic training.
(11) Safety system certification/validation. (i) Prior to the initial use of any
mechanical press in the PSDI mode,
two sets of certification and validation
are required:
(A) The design of the safety system
required for the use of a press in the
PSDI mode shall be certified and validated prior to installation. The manufacturer’s certification shall be validated by an OSHA-recognized thirdparty validation organization to meet
all applicable requirements of paragraphs (a) through (h) and appendix A
of this section.
(B) After a press has been equipped
with a safety system whose design has
been certified and validated in accordance with paragraph (h)(11)(i) of this
section, the safety system installation
shall be certified by the employer, and
then shall be validated by an OSHArecognized third-party validation organization to meet all applicable requirements of paragraphs (a) through (h)
and appendix A of this section.
(ii) At least annually thereafter, the
safety system on a mechanical power
press used in the PSDI mode shall be

§ 1910.217

recertified by the employer and revalidated by an OSHA-recognized thirdparty validation organization to meet
all applicable requirements of paragraphs (a) through (h) and appendix A
of this section. Any press whose safety
system has not been recertified and revalidated within the preceding 12
months shall be removed from service
in the PSDI mode until the safety system is recertified and revalidated.
(iii) A label shall be affixed to the
press as part of each installation certification/validation and the most recent recertification/revalidation. The
label shall indicate the press serial
number, the minimum safety distance
(Ds) required by paragraph (h)(9)(v) of
this section, the fulfillment of design
certification/validation, the employer’s
signed certification, the identification
of the OSHA-recognized third-party
validation organization, its signed validation, and the date the certification/
validation and recertification/revalidation are issued.
(iv) Records of the installation certification and validation and the most
recent recertification and revalidation
shall be maintained for each safety system equipped press by the employer as
long as the press is in use. The records
shall include the manufacture and
model number of each component and
subsystem, the calculations of the safety distance as required by paragraph
(h)(9)(v) of this section, and the stopping time measurements required by
paragraph (h)(2)(ii) of this section. The
most recent records shall be made
available to OSHA upon request.
(v) The employer shall notify the
OSHA-recognized third-party validation organization within five days
whenever a component or a subsystem
of the safety system fails or modifications are made which may affect the
safety of the system. The failure of a
critical component shall necessitate
the removal of the safety system from
service until it is recertified and revalidated, except recertification by the
employer without revalidation is permitted when a non-critical component
or subsystem is replaced by one of the
same manufacture and design as the
original, or determined by the thirdparty validation organization to be

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

equivalent by similarity analysis, as
set forth in appendix A.
(vi) The employer shall notify the
OSHA-recognized third-party validation organization within five days of
the occurrence of any point of operation injury while a press is used in the
PSDI mode. This is in addition to the
report of injury required by paragraph
(g) of this section; however, a copy of
that report may be used for this purpose.
(12) Die setting and work set-up. (i) Die
setting on presses used in the PSDI
mode shall be performed in accordance
with paragraphs (d) and (h) of this section.
(ii) The PSDI mode shall not be used
for die setting or set-up. An alternative
manual cycle initiation and control
means shall be supplied for use in die
setting which meets the requirements
of paragraph (b)(7) of this section.
(iii) Following a die change, the safety distance, the proper application of
supplemental safeguarding, and the
slide counterbalance adjustment (if the
press is equipped with a counterbalance) shall be checked and maintained by authorized persons whose
qualifications include knowledge of the
safety distance, supplemental safeguarding requirements, and the manufacturer’s specifications for counterbalance adjustment. Adjustment of the
location of the PSDI presence sensing
device shall require use of a special
tool available only to the authorized
persons.
(13) Operator training. (i) The operator
training required by paragraph (f)(2) of
this section shall be provided to the
employee before the employee initially
operates the press and as needed to
maintain competence, but not less
than annually thereafter. It shall include instruction relative to the following items for presses used in the
PSDI mode.
(A)
The
manufacturer’s
recommended test procedures for checking operation of the presence sensing
device. This shall include the use of the
test rod required by paragraph (h)(10)(i)
of this section.
(B) The safety distance required.
(C) The operation, function and performance of the PSDI mode.

(D) The requirements for hand tools
that may be used in the PSDI mode.
(E) The severe consequences that can
result if he or she attempts to circumvent or by-pass any of the safeguard or operating functions of the
PSDI system.
(ii) The employer shall certify that
employees have been trained by preparing a certification record which includes the identity of the person
trained, the signature of the employer
or the person who conducted the training, and the date the training was completed. The certification record shall
be prepared at the completion of training and shall be maintained on file for
the duration of the employee’s employment. The certification record shall be
made available upon request to the Assistant Secretary for Occupational
Safety and Health.
APPENDIX A TO § 1910.217—MANDATORY REQUIREMENTS FOR CERTIFICATION/VALIDATION
OF SAFETY SYSTEMS FOR PRESENCE SENSING
DEVICE INITIATION OF MECHANICAL POWER
PRESSES
Purpose
The purpose of the certification/validation
of safety systems for presence sensing device
initiation (PSDI) of mechanical power presses is to ensure that the safety systems are
designed, installed, and maintained in accordance with all applicable requirements of
29 CFR 1910.217 (a) through (h) and this appendix A.
General
The certification/validation process shall
utilize an independent third-party validation
organization recognized by OSHA in accordance with the requirements specified in appendix C of this section.
While the employer is responsible for assuring that the certification/validation requirements in § 1910.217(h)(11) are fulfilled,
the design certification of PSDI safety systems may be initiated by manufacturers, employers, and/or their representatives. The
term manufacturers refers to the manufacturer of any of the components of the safety
system. An employer who assembles a PSDI
safety system would be a manufacturer as
well as employer for purposes of this standard and appendix.
The certification/validation process includes two stages. For design certification,
in the first stage, the manufacturer (which
can be an employer) certifies that the PSDI
safety system meets the requirements of 29
CFR 1910.217 (a) through (h) and this appendix A, based on appropriate design criteria

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Occupational Safety and Health Admin., Labor
and tests. In the second stage, the OSHA-recognized third-party validation organization
validates that the PSDI safety system meets
the requirements of 29 CFR 1910.217 (a)
through (h) and this appendix A and the
manufacturer’s certification by reviewing
the manufacturer’s design and test data and
performing any additional reviews required
by this standard or which it believes appropriate.
For installation certification/validation
and annual recertification/revalidation, in
the first stage the employer certifies or recertifies that the employer is installing or
utilizing a PSDI safety system validated as
meeting the design requirements of 29 CFR
1910.217 (a) through (h) and this appendix A
by an OSHA-recognized third-party validation organization and that the installation,
operation and maintenance meet the requirements of 29 CFR 1910.217 (a) through (h)
and this appendix A. In the second stage, the
OSHA-recognized third-party validation organization validates or revalidates that the
PSDI safety system installation meets the
requirements of 29 CFR 1910.217 (a) through
(h) and this appendix A and the employer’s
certification, by reviewing that the PSDI
safety system has been certified; the employer’s certification, designs and tests, if any;
the installation, operation, maintenance and
training; and by performing any additional
tests and reviews which the validation organization believes is necessary.
Summary
The certification/validation of safety systems for PSDI shall consider the press, controls, safeguards, operator, and environment
as an integrated system which shall comply
with all of the requirements in 29 CFR
1910.217 (a) through (h) and this appendix A.
The certification/validation process shall
verify that the safety system complies with
the OSHA safety requirements as follows:

§ 1910.217

B. Installation Certification/Validation
1. The employer shall certify that the
PSDI safety system has been design certified
and validated, that the installation meets
the operational and environmental requirements specified by the manufacturer, that
the installation drawings are accurate, and
that the installation meets the requirements
of 29 CFR 1910.217 (a) through (h) and this appendix A. (The operational and installation
requirements of the PSDI safety system may
vary for different applications.)
2. The third-party validation organization
shall validate the employer’s certifications
that the PSDI safety system is design certified and validated, that the installation
meets the installation and environmental requirements specified by the manufacturer,
and that the installation meets the requirements of 29 CFR 1910.217 (a) through (h) and
this appendix A.
C. Recertification/Revalidation
1. The PSDI safety system shall remain
under certification/validation for the shorter
of one year or until the system hardware is
changed, modified or refurbished, or operating conditions are changed (including environmental, application or facility changes),
or a failure of a critical component has occurred.
2. Annually, or after a change specified in
paragraph 1., the employer shall inspect and
recertify the installation as meeting the requirements set forth under B., Installation
Certification/Validation.
3. The third-party validation organization,
annually or after a change specified in paragraph 1., shall validate the employer’s certification that the requirements of paragraph B., Installation Certification/Validation have been met.
(NOTE: Such changes in operational conditions as die changes or press relocations not
involving disassembly or revision to the
safety system would not require recertification/revalidation.)

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A. Design Certification/Validation
1. The major parts, components and subsystems used shall be defined by part number
or serial number, as appropriate, and by
manufacturer to establish the configuration
of the system.
2. The identified parts, components and
subsystems shall be certified by the manufacturer to be able to withstand the functional and operational environments of the
PSDI safety system.
3. The total system design shall be certified by the manufacturer as complying
with all requirements in 29 CFR 1910.217 (a)
through (h) and this appendix A.
4. The third-party validation organization
shall validate the manufacturer’s certification under paragraphs 2 and 3.

Certification/Validation Requirements
A. General Design Certification/Validation
Requirements
1. Certification/Validation Program Requirements. The manufacturer shall certify and
the OSHA-recognized third-party validation
organization shall validate that:
(a) The design of components, subsystems,
software and assemblies meets OSHA performance requirements and are ready for the
intended use; and
(b) The performance of combined subsystems meets OSHA’s operational requirements.
2. Certification/Validation Program Level of
Risk Evaluation Requirements. The manufacturer shall evaluate and certify, and the

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

OSHA-recognized third-party validation organization shall validate, the design and operation of the safety system by determining
conformance with the following:
a. The safety system shall have the ability
to sustain a single failure or a single operating error and not cause injury to personnel
from point of operation hazards. Acceptable
design features shall demonstrate, in the following order or precedence, that:
(1) No single failure points may cause injury; or
(2) Redundancy, and comparison and/or diagnostic checking, exist for the critical
items that may cause injury, and the electrical, electronic, electromechanical and mechanical parts and components are selected
so that they can withstand operational and
external environments. The safety factor
and/or derated percentage shall be specifically noted and complied with.
b. The manufacturer shall design, evaluate,
test and certify, and the third-party validation organization shall evaluate and validate, that the PSDI safety system meets appropriate requirements in the following
areas.
(1) Environmental Limits
(a) Temperature
(b) Relative humidity
(c) Vibration
(d) Fluid compatability with other materials
(2) Design Limits
(a) Power requirements
(b) Power transient tolerances
(c) Compatability of materials used
(d) Material stress tolerances and limits
(e) Stability to long term power fluctuations
(f) Sensitivity to signal acquisition
(g) Repeatability of measured parameter
without inadvertent initiation of a press
stroke
(h) Operational life of components in cycles, hours, or both
(i) Electromagnetic tolerance to:
(1) Specific operational wave lengths; and
(2) Externally generated wave lengths
(3) New Design Certification/Validation. Design certification/validation for a new safety
system, i.e., a new design or new integration
of specifically identified components and
subsystems, would entail a single certification/validation which would be applicable
to all identical safety systems. It would not
be necessary to repeat the tests on individual safety systems of the same manufacture or design. Nor would it be necessary to
repeat these tests in the case of modifications where determined by the manufacturer
and validated by the third-party validation
organization to be equivalent by similarity
analysis. Minor modifications not affecting
the safety of the system may be made by the
manufacturer without revalidation.

Substantial modifications would require
testing as a new safety system, as deemed
necessary by the validation organization.
B. Additional Detailed Design Certification/
Validation Requirements
1. General. The manufacturer or the manufacturer’s representative shall certify to and
submit to an OSHA-recognized third-party
validation organization the documentation
necessary to demonstrate that the PSDI
safety system design is in full compliance
with the requirements of 29 CFR 1910.217(a)–
(h) and this appendix A, as applicable, by
means of analysis, tests, or combination of
both, establishing that the following additional certification/validation requirements
are fulfilled.
2. Reaction Times. For the purpose of demonstrating compliance with the reaction
time required by § 1910.217(h), the tests shall
use the following definitions and requirements:
a. Reaction time means the time, in seconds,
it takes the signal, required to activate/deactivate the system, to travel through the
system, measured from the time of signal
initiation to the time the function being
measured is completed.
b. Full stop or No movement of the slide or
ram means when the crankshaft rotation has
slowed to two or less revolutions per minute,
just before stopping completely.
c. Function completion means for, electrical,
electromechanical and electronic devices,
when the circuit produces a change of state
in the output element of the device.
d. When the change of state is motion, the
measurement shall be made at the completion of the motion.
e. The generation of the test signal introduced into the system for measuring reaction time shall be such that the initiation
time can be established with an error of less
than 0.5 percent of the reaction time measured.
f. The instrument used to measure reaction
time shall be calibrated to be accurate to
within 0.001 second.
3. Compliance with § 1910.217(h)(2)(ii). For
compliance with these requirements, the average value of the stopping time, Ts, shall be
the arithmetic mean of at least 25 stops for
each stop angle initiation measured with the
brake and/or clutch unused, 50 percent worn,
and 90 percent worn. The recommendations
of the brake system manufacturer shall be
used to simulate or estimate the brake wear.
The manufacturer’s recommended minimum
lining depth shall be identified and documented, and an evaluation made that the
minimum depth will not be exceeded before
the next (annual) recertification/revalidation. A correlation of the brake and/or clutch
degradation based on the above tests and/or
estimates shall be made and documented.
The results shall document the conditions

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Occupational Safety and Health Admin., Labor
under which the brake and/or clutch will and
will not comply with the requirement. Based
upon this determination, a scale shall be developed to indicate the allowable 10 percent
of the stopping time at the top of the stroke
for slide or ram overtravel due to brake
wear. The scale shall be marked to indicate
that brake adjustment and/or replacement is
required. The explanation and use of the
scale shall be documented.
The test specification and procedure shall
be submitted to the validation organization
for review and validation prior to the test.
The validation organization representative
shall witness at least one set of tests.
4. Compliance with §§ 1910.217(h)(5)(iii) and
(h)(9)(v). Each reaction time required to calculate the Safety Distance, including the
brake monitor setting, shall be documented
in separate reaction time tests. These tests
shall specify the acceptable tolerance band
sufficient to assure that tolerance build-up
will not render the safety distance unsafe.
a. Integrated test of the press fully
equipped to operate in the PSDI mode shall
be conducted to establish the total system
reaction time.
b. Brakes which are the adjustable type
shall be adjusted properly before the test.
5. Compliance with § 1910.217(h)(2)(iii). a.
Prior to conducting the brake system test
required by paragraph (h)(2)(ii), a visual
check shall be made of the springs. The visual check shall include a determination that
the spring housing or rod does not show damage sufficient to degrade the structural integrity of the unit, and the spring does not
show any tendency to interleave.
b. Any detected broken or unserviceable
springs shall be replaced before the test is
conducted. The test shall be considered successful if the stopping time remains within
that which is determined by paragraph
(h)(9)(v) for the safety distance setting. If the
increase in press stopping time exceeds the
brake monitor setting limit defined in paragraph (h)(5)(iii), the test shall be considered
unsuccessful, and the cause of the excessive
stopping time shall be investigated. It shall
be ascertained that the springs have not
been broken and that they are functioning
properly.
6. Compliance with § 1910.217(h)(7). a. Tests
which are conducted by the manufacturers of
electrical components to establish stress,
life, temperature and loading limits must be
tests which are in compliance with the provisions of the National Electrical Code.
b. Electrical and/or electronic cards or
boards assembled with discreet components
shall be considered a subsystem and shall require separate testing that the subsystems
do not degrade in any of the following conditions:
(1) Ambient temperature variation from
¥20° C to +50° C.

§ 1910.217

(2) Ambient relative humidity of 99 percent.
(3) Vibration of 45G for one millisecond per
stroke when the item is to be mounted on
the press frame.
(4) Electromagnetic interference at the
same wavelengths used for the radiation
sensing field, at the power line frequency
fundamental and harmonics, and also from
outogenous radiation due to system switching.
(5) Electrical power supply variations of
±15 percent.
c. The manufacturer shall specify the test
requirements and procedures from existing
consensus tests in compliance with the provisions of the National Electrical Code.
d. Tests designed by the manufacturer
shall be made available upon request to the
validation organization. The validation organization representative shall witness at least
one set of each of these tests.
7. Compliance with § 1910.217(h)(9)(iv). a. The
manufacturer shall design a test to demonstrate that the prescribed minimum object
sensitivity of the presence sensing device is
met.
b. The test specifications and procedures
shall be made available upon request to the
validation organization.
8. Compliance with § 1910.217(h)(9)(x). a. The
manufacturer shall design a test(s) to establish the hand tool extension diameters allowed for variations in minimum object sensitivity response.
b. The test(s) shall document the range of
object diameter sizes which will produce
both single and double break conditions.
c. The test(s) specifications and procedures
shall be made available upon request to the
validation organization.
9. Integrated Tests Certification/Validation. a.
The manufacturer shall design a set of integrated tests to demonstrate compliance with
the following requirements:
Sections 1910.217(h)(6) (ii); (iii); (iv); (v);
(vi); (vii); (viii); (ix); (xi); (xii); (xiii); (xiv);
(xv); and (xvii).
b. The integrated test specifications and
procedures shall be made available to the
validation organization.
10. Analysis. a. The manufacturer shall submit to the validation organization the technical analysis such as Hazard Analysis, Failure Mode and Effect Analysis, Stress Analysis, Component and Material Selection
Analysis, Fluid Compatability, and/or other
analyses which may be necessary to demonstrate, compliance with the following requirements:
Sections 1910.217(h)(8) (i) and (ii); (h)(2) (ii)
and (iii); (h)(3)(i) (A) and (C), and (ii); (h)(5)
(i), (ii) and (iii); (h)(6) (i), (iii), (iv), (vi), (vii),
(viii), (ix), (x), (xi), (xiii), (xiv), (xv), (xvi),
and (xvii); (h)(7) (i) and (ii); (h)(9) (iv), (v),
(viii), (ix) and (x); (h)(10) (i) and (ii).

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

11. Types of Tests Acceptable for Certification/
Validation. a. Test results obtained from development testing may be used to certify/
validate the design.
b. The test results shall provide the engineering data necessary to establish confidence that the hardware and software will
meet specifications, the manufacturing process has adequate quality control and the
data acquired was used to establish processes, procedures, and test levels supporting
subsequent hardware design, production, installation and maintenance.
12. Validation for Design Certification/Validation. If, after review of all documentation,
tests, analyses, manufacturer’s certifications, and any additional tests which the
third-party validation organization believes
are necessary, the third-party validation organization determines that the PSDI safety
system is in full compliance with the applicable requirements of 29 CFR 1910.217(a)
through (h) and this appendix A, it shall
validate the manufacturer’s certification
that it so meets the stated requirements.
C. Installation Certification/Validation
Requirements
1. The employer shall evaluate and test the
PSDI system installation, shall submit to
the OSHA-recognized third-party validation
organization the necessary supporting documentation, and shall certify that the requirements of § 1910.217(a) through (h) and
this appendix A have been met and that the
installation is proper.
2. The OSHA-recognized third-party validation organization shall conduct tests, and/or
review and evaluate the employer’s installation tests, documentation and representations. If it so determines, it shall validate
the employer’s certification that the PSDI
safety system is in full conformance with all
requirements of 29 CFR 1910.217(a) through
(h) and this appendix A.

2. Conduct or recertification/revalidation. The
employer shall evaluate and test the PSDI
safety system installation, shall submit to
the OSHA-recognized third-party validation
organization the necessary supporting documentation, and shall recertify that the requirements of § 1910.217(a) through (h) and
this appendix are being met. The documentation shall include, but not be limited to, the
following items:
a. Demonstration of a thorough inspection
of the entire press and PSDI safety system
to ascertain that the installation, components and safeguarding have not been
changed, modified or tampered with since
the installation certification/validation or
last recertification/revalidation was made.
b. Demonstrations that such adjustments
as may be needed (such as to the brake monitor setting) have been accomplished with
proper changes made in the records and on
such notices as are located on the press and
safety system.
c. Demonstration that review has been
made of the reports covering the design certification/validation, the installation certification/validation, and all recertification/revalidations, in order to detect any degradation to an unsafe condition, and that necessary changes have been made to restore
the safety system to previous certification/
validation levels.
3. The OSHA-recognized third-party validation organization shall conduct tests, and/or
review and evaluate the employer’s installation, tests, documentation and representations. If it so determines, it shall revalidate
the employer’s recertification that the PSDI
system is in full conformance with all requirements of 29 CFR 1910.217(a) through (h)
and this appendix A.
APPENDIX B TO § 1910.217—NONMANDATORY
GUIDELINES FOR CERTIFICATION/VALIDATION
OF SAFETY SYSTEMS FOR PRESENCE SENSING
DEVICE INITIATION OF MECHANICAL POWER
PRESSES

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D. Recertification/Revalidation
Requirements

Objectives

1. A PSDI safety system which has received installation certification/validation
shall undergo recertification/revalidation
the earlier of:
a. Each time the systems hardware is significantly changed, modified, or refurbished;
b. Each time the operational conditions
are significantly changed (including environmental, application or facility changes, but
excluding such changes as die changes or
press relocations not involving revision to
the safety system);
c. When a failure of a significant component has occurred or a change has been made
which may affect safety; or
d. When one year has elapsed since the installation certification/validation or the last
recertification/revalidation.

This appendix provides employers, manufacturers, and their representatives, with
nonmandatory guidelines for use in developing certification documents. Employers
and manufacturers are encouraged to recommend other approaches if there is a potential for improving safety and reducing cost.
The guidelines apply to certification/validation activity from design evaluation through
the completion of the installation test and
the annual recertification/revalidation tests.
General Guidelines
A. The certification/validation process
should confirm that hazards identified by
hazard analysis, (HA), failure mode effect
analysis (FMEA), and other system analyses
have been eliminated by design or reduced to

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Occupational Safety and Health Admin., Labor
an acceptable level through the use of appropriate design features, safety devices, warning devices, or special procedures. The certification/validation process should also confirm that residual hazards identified by operational analysis are addressed by warning,
labeling safety instructions or other appropriate means.
B. The objective of the certification/validation program is to demonstrate and document that the system satisfies specification
and operational requirements for safe operations.
Quality Control
The safety attributes of a certified/validated PSDI safety system are more likely to
be maintained if the quality of the system
and its parts, components and subsystem is
consistently controlled. Each manufacturer
supplying parts, components, subsystems,
and assemblies needs to maintain the quality
of the product, and each employer needs to
maintain the system in a non-degraded condition.
Analysis Guidelines
A. Certification/validation of hardware design below the system level should be accomplished by test and/or analysis.
B. Analytical methods may be used in lieu
of, in combination with, or in support of
tests to satisfy specification requirements.
C. Analyses may be used for certification/
validation when existing data are available
or when test is not feasible.
D. Similarity analysis may be used in lieu
of tests where it can be shown that the article is similar in design, manufacturing process, and quality control to another article
that was previously certified/validated in accordance with equivalent or more stringent
criteria. If previous design, history and application are considered to be similar, but
not equal to or more exacting than earlier
experiences, the additional or partial certification/validation tests should concentrate on
the areas of changed or increased requirements.

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Analysis Reports
The analysis reports should identify: (1)
The basis for the analysis; (2) the hardware
or software items analyzed; (3) conclusions;
(4) safety factors; and (5) limit of the analysis. The assumptions made during the analysis should be clearly stated and a description of the effects of these assumptions on
the conclusions and limits should be included.
Certification/validation by similarity analysis reports should identify, in addition to
the above, application of the part, component or subsystem for which certification/
validation is being sought as well as data
from previous usage establishing adequacy of

§ 1910.217

the item. Similarity analysis should not be
accepted when the internal and external
stresses on the item being certified/validated
are not defined.
Usage experience should also include failure data supporting adequacy of the design.
APPENDIX C TO § 1910.217—MANDATORY REQUIREMENTS FOR OSHA RECOGNITION OF
THIRD-PARTY VALIDATION ORGANIZATIONS
FOR THE PSDI STANDARD
This appendix prescribes mandatory requirements and procedures for OSHA recognition of third-party validation organizations to validate employer and manufacturer
certifications that their equipment and practices meet the requirements of the PSDI
standard. The scope of the appendix includes
the three categories of certification/validation required by the PSDI standard: Design
Certification/Validation, Installation Certification/Validation, and Annual Recertification/Revalidation.
If further detailing of these provisions will
assist the validation organization or OSHA
in this activity, this detailing will be done
through appropriate OSHA Program Directives.
I. Procedure for OSHA Recognition of
Validation Organizations
A. Applications
1. Eligibility. a. Any person or organization
considering itself capable of conducting a
PSDI-related third-party validation function
may apply for OSHA recognition.
b. However, in determining eligibility for a
foreign-based third-party validation organization, OSHA shall take into consideration
whether there is reciprocity of treatment by
the foreign government after consultation
with relevant U.S. government agencies.
2. Content of application. a. The application
shall identify the scope of the validation activity for which the applicant wishes to be
recognized, based on one of the following alternatives:
(1) Design Certification/Validation, Installation Certification/Validation, and Annual
Recertification/Revalidation;
(2) Design Certification/Validation only; or
(3)
Installation/Certification/Validation
and Annual Recertification/Revalidation.
b. The application shall provide information demonstrating that it and any validating laboratory utilized meet the qualifications set forth in section II of this appendix.
c. The applicant shall provide information
demonstrating that it and any validating
laboratory utilized meet the program requirements set forth in section III of this appendix.
d. The applicant shall identify the test
methods it or the validating laboratory will

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

use to test or judge the components and operations of the PSDI safety system required
to be tested by the PSDI standard and appendix A, and shall specify the reasons the test
methods are appropriate.
e. The applicant may include whatever enclosures, attachments, or exhibits the applicant deems appropriate. The application
need not be submitted on a Federal form.
f. The applicant shall certify that the information submitted is accurate.
3. Filing office location. The application
shall be filed with: PSDI Certification/Validation Program, Office of Variance Determination, Occupational Safety and Health
Administration, U.S. Department of Labor,
Room N3653, 200 Constitution Avenue, NW.,
Washington, DC 20210.
4. Amendments and withdrawals. a. An application may be revised by an applicant at any
time prior to the completion of the final
staff recommendation.
b. An application may be withdrawn by an
applicant, without prejudice, at any time
prior to the final decision by the Assistant
Secretary in paragraph I.B.8.b.(4) of this appendix.

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B. Review and Decision Process
1. Acceptance and field inspection. All applications submitted will be accepted by OSHA,
and their receipt acknowledged in writing.
After receipt of an application, OSHA may
request additional information if it believes
information relevant to the requirements for
recognition have been omitted. OSHA may
inspect the facilities of the third-party validation organization and any validating laboratory, and while there shall review any additional documentation underlying the application. A report shall be made of each
field inspection.
2. Requirements for recognition. The requirements for OSHA recognition of a third-party
validation organization for the PSDI standard are that the program has fulfilled the requirements of section II of this appendix for
qualifications and of section III of this appendix for program requirements, and the
program has identified appropriate test and
analysis methods to meet the requirements
of the PSDI standard and appendix A.
3. Preliminary approval. If, after review of
the application, any additional information,
and the inspection report, the applicant and
any validating laboratory appear to have
met the requirements for recognition, a written recommendation shall be submitted by
the responsible OSHA personnel to the Assistant Secretary to approve the application
with a supporting explanation.
4. Preliminary disapproval. If, after review of
the application, additional information, and
inspection report, the applicant does not appear to have met the requirements for recognition, the Director of the PSDI certification/validation program shall notify the

applicant in writing, listing the specific requirements of this appendix which the applicant has not met, and the reasons.
5. Revision of application. After receipt of a
notification of preliminary disapproval, the
applicant may submit a revised application
for further review by OSHA pursuant to subsection I.B. of this appendix or may request
that the original application be submitted to
the Assistant Secretary with a statement of
reasons supplied by the applicant as to why
the application should be approved.
6. Preliminary decision by Assistant Secretary.
a. The Assistant Secretary, or a special designee for this purpose, will make a preliminary decision whether the applicant has met
the requirements for recognition based on
the completed application file and the written staff recommendation, as well as the
statement of reasons by the applicant if
there is a recommendation of disapproval.
b. This preliminary decision will be sent to
the applicant and subsequently published in
the FEDERAL REGISTER.
7. Public review and comment period. a. The
FEDERAL REGISTER notice of preliminary decision will provide a period of not less than
60 calendar days for the written comments
on the applicant’s fulfillment of the requirements for recognition. The application, supporting documents, staff recommendation,
statement of applicant’s reasons, and any
comments received, will be available for public inspection in the OSHA Docket Office.
b. If the preliminary decision is in favor of
recognition, a member of the public, or if the
preliminary decision is against recognition,
the applicant may request a public hearing
by the close of the comment period, if it supplies detailed reasons and evidence challenging the basis of the Assistant Secretary’s preliminary decision and justifying
the need for a public hearing to bring out
evidence which could not be effectively supplied through written submissions.
8. Final decision by Assistant Secretary—a.
Without hearing. If there are no valid requests for a hearing, based on the application, supporting documents, staff recommendation, evidence and public comment,
the Assistant Secretary shall issue the final
decision (including reasons) of the Department of Labor on whether the applicant has
demonstrated by a preponderance of the evidence that it meets the requirements for recognition.
b. After hearing. If there is a valid request
for a hearing pursuant to paragraph I.B.7.b.
of this appendix, the following procedures
will be used:
(1) The Assistant Secretary will issue a notice of hearing before an administrative law
judge of the Department of Labor pursuant
to the rules specified in 29 CFR part 1905,
subpart C.
(2) After the hearing, pursuant to subpart
C, the administrative law judge shall issue a

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Occupational Safety and Health Admin., Labor
decision (including reasons) based on the application, the supporting documentation, the
staff recommendation, the public comments
and the evidence submitted during the hearing (the record), stating whether it has been
demonstrated, based on a preponderance of
evidence, that the applicant meets the requirements for recognition. If no exceptions
are filed, this is the final decision of the Department of Labor.
(3) Upon issuance of the decision, any
party to the hearing may file exceptions
within 20 days pursuant to subpart C. If exceptions are filed, the administrative law
judge shall forward the decision, exceptions
and record to the Assistant Secretary for the
final decision on the application.
(4) The Assistant Secretary shall review
the record, the decision by the administrative law judge, and the exceptions. Based on
this, the Assistant Secretary shall issue the
final decision (including reasons) of the Department of Labor stating whether the applicant has demonstrated by a preponderance of
evidence that it meets the requirements for
recognition.
b. Publication. A notification of the final
decision shall be published in the FEDERAL
REGISTER.

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C. Terms and Conditions of Recognition,
Renewal and Revocation
1. The following terms and conditions shall
be part of every recognition:
a. The recognition of any validation organization will be evidenced by a letter of recognition from OSHA. The letter will provide
the specific details of the scope of the OSHA
recognition as well as any conditions imposed by OSHA, including any Federal monitoring requirements.
b. The recognition of each validation organization will be valid for five years, unless
terminated before or renewed after the expiration of the period. The dates of the period
of recognition will be stated in the recognition letter.
c. The recognized validation organization
shall continue to satisfy all the requirements of this appendix and the letter of recognition during the period of recognition.
2. A recognized validation organization
may change a test method of the PSDI safety system certification/validation program
by notifying the Assistant Secretary of the
change, certifying that the revised method
will be at least as effective as the prior
method, and providing the supporting data
upon which its conclusions are based.
3. A recognized validation organization
may renew its recognition by filing a renewal request at the address in paragraph
I.A.3. of this appendix, above, not less than
180 calendar days, nor more than one year,
before the expiration date of its current recognition. When a recognized validation organization has filed such a renewal request, its

§ 1910.217

current recognition will not expire until a
final decision has been made on the request.
The renewal request will be processed in accordance with subsection I.B. of this appendix, above, except that a reinspection is not
required but may be performed by OSHA. A
hearing will be granted to an objecting member of the public if evidence of failure to
meet the requirements of this appendix is
supplied to OSHA.
4. A recognized validation organization
may apply to OSHA for an expansion of its
current recognition to cover other categories
of PSDI certification/validation in addition
to those included in the current recognition.
The application for expansion will be acted
upon and processed by OSHA in accordance
with subsection I.B. of this appendix, subject
to the possible reinspection exception. If the
validation organization has been recognized
for more than one year, meets the requirements for expansion of recognition, and
there is no evidence that the recognized validation organization has not been following
the requirements of this appendix and the
letter of recognition, an expansion will normally be granted. A hearing will be granted
to an objecting member of the public only if
evidence of failure to meet the requirements
of this appendix is supplied to OSHA.
5. A recognized validation organization
may voluntarily terminate its recognition,
either in its entirety or with respect to any
area covered in its recognition, by giving
written notice to OSHA at any time. The
written notice shall indicate the termination
date. A validation organization may not terminate its installation certification and recertification validation functions earlier
than either one year from the date of the
written notice, or the date on which another
recognized validation organization is able to
perform the validation of installation certification and recertification.
6.a. OSHA may revoke its recognition of a
validation organization if its program either
has failed to continue to satisfy the requirements of this appendix or its letter of recognition, has not been performing the validation functions required by the PSDI standard
and appendix A, or has misrepresented itself
in its applications. Before proposing to revoke recognition, the Agency will notify the
recognized validation organization of the
basis of the proposed revocation and will
allow rebuttal or correction of the alleged
deficiencies. If the deficiencies are not corrected, OSHA may revoke recognition, effective in 60 days, unless the validation organization requests a hearing within that time.
b. If a hearing is requested, it shall be held
before an administrative law judge of the Department of Labor pursuant to the rules
specified in 29 CFR part 1905, subpart C.

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

c. The parties shall be OSHA and the recognized validation organization. The decision shall be made pursuant to the procedures specified in paragraphs I.B.8.b.(2)
through (4) of this appendix except that the
burden of proof shall be on OSHA to demonstrate by a preponderance of the evidence
that the recognition should be revoked because the validation organization either is
not meeting the requirements for recognition, has not been performing the validation
functions required by the PSDI standard and
appendix A, or has misrepresented itself in
its applications.
D. Provisions of OSHA Recognition
Each recognized third-party validation organization and its validating laboratories
shall:
1. Allow OSHA to conduct unscheduled reviews or on-site audits of it or the validating
laboratories on matters relevant to PSDI,
and cooperate in the conduct of these reviews and audits;
2. Agree to terms and conditions established by OSHA in the grant of recognition
on matters such as exchange of data, submission of accident reports, and assistance in
studies for improving PSDI or the certification/validation process.
II. Qualifications

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The third-party validation organization,
the validating laboratory, and the employees
of each shall meet the requirements set forth
in this section of this appendix.

a. It is financially capable to conduct the
work;
b. It is free of direct influence or control
by manufacturers, suppliers, vendors, representatives of employers and employees,
and employer or employee organizations; and
c. Its employees are secure from discharge
resulting from pressures from manufacturers, suppliers, vendors, employers or employee representatives.
2. A validation organization may be considered independent even if it has ties with
manufacturers, employers or employee representatives if these ties are with at least
two of these three groups; it has a board of
directors (or equivalent leadership responsible for the certification/validation activities) which includes representatives of the
three groups; and it has a binding commitment of funding for a period of three years or
more.
C. Validating Laboratory
The validation organization’s laboratory
(which organizationally may be a part of the
third-party validation organization):
1. Shall have legal authority to perform
the validation of certification;
2. Shall be free of operational control and
influence of manufacturers, suppliers, vendors, employers, or employee representatives
that would impair its integrity of performance; and
3. Shall not engage in the design, manufacture, sale, promotion, or use of the certified
equipment.

A. Experience of Validation Organization

D. Facilities and Equipment

1. The third-party validation organization
shall have legal authority to perform certification/validation activities.
2. The validation organization shall demonstrate competence and experience in either power press design, manufacture or use,
or testing, quality control or certification/
validation of equipment comparable to
power presses and associated control systems.
3. The validation organization shall demonstrate a capability for selecting, reviewing, and/or validating appropriate standards
and test methods to be used for validating
the certification of PSDI safety systems, as
well as for reviewing judgements on the safety of PSDI safety systems and their conformance with the requirements of this section.
4. The validating organization may utilize
the competence, experience, and capability
of its employees to demonstrate this competence, experience and capability.

The validation organization’s validating
laboratory shall have available all testing
facilities and necessary test and inspection
equipment relevant to the validation of the
certification of PSDI safety systems, installations and operations.

B. Independence of Validation Organization
1. The validation organization shall demonstrate that:

E. Personnel
The validation organization and the validating laboratory shall be adequately staffed
by personnel who are qualified by technical
training and/or experience to conduct the
validation of the certification of PSDI safety
systems.
1. The validation organization shall assign
overall responsibility for the validation of
PSDI certification to an Administrative Director. Minimum requirements for this position are a Bachelor’s degree and five years
professional experience, at least one of which
shall have been in responsible charge of a
function in the areas of power press design or
manufacture or a broad range of power press
use, or in the areas of testing, quality control, or certification/validation of equipment
comparable to power presses or their associated control systems.

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Occupational Safety and Health Admin., Labor
2. The validating laboratory, if a separate
organization from the validation organization, shall assign technical responsibility for
the validation of PSDI certification to a
Technical Director. Minimum requirements
for this position are a Bachelor’s degree in a
technical field and five years of professional
experience, at least one of which shall have
been in responsible charge of a function in
the area of testing, quality control or certification/validation of equipment comparable
to power presses or their associated control
systems.
3. If the validation organization and the
validating laboratory are the same organization, the administrative and technical responsibilities may be combined in a single
position, with minimum requirements as described in E.1. and 2. for the combined position.
4. The validation organization and validating laboratory shall have adequate administrative and technical staffs to conduct
the validation of the certification of PSDI
safety systems.
F. Certification/Validation Mark or Logo
1. The validation organization or the validating laboratory shall own a registered certification/validation mark or logo.
2. The mark or logo shall be suitable for incorporation into the label required by paragraph (h)(11)(iii) of this section.
III. Program Requirements
A. Test and Certification/Validation
Procedures
1. The validation organization and/or validating laboratory shall have established
written procedures for test and certification/
validation of PSDI safety systems. The procedures shall be based on pertinent OSHA
standards and test methods, or other publicly available standards and test methods
generally recognized as appropriate in the
field, such as national consensus standards
or published standards of professional societies or trade associations.
2. The written procedures for test and certification/validation of PSDI systems, and
the standards and test methods on which
they are based, shall be reproducible and be
available to OSHA and to the public upon request.

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B. Test Reports
1. A test report shall be prepared for each
PSDI safety system that is tested. The test
report shall be signed by a technical staff
representative and the Technical Director.
2. The test report shall include the following:
a. Name of manufacturer and catalog or
model number of each subsystem or major
component.

§ 1910.217

b. Identification and description of test
methods or procedures used. (This may be
through reference to published sources which
describe the test methods or procedures
used.)
c. Results of all tests performed.
d. All safety distance calculations.
3. A copy of the test report shall be maintained on file at the validation organization
and/or validating laboratory, and shall be
available to OSHA upon request.
C. Certification/Validation Reports
1. A certification/validation report shall be
prepared for each PSDI safety system for
which the certification is validated. The certification/validation report shall be signed
by the Administrative Director and the
Technical Director.
2. The certification/validation report shall
include the following:
a. Name of manufacturer and catalog or
model number of each subsystem or major
component.
b. Results of all tests which serve as the
basis for the certification.
c. All safety distance calculations.
d. Statement that the safety system conforms with all requirements of the PSDI
standard and appendix A.
3. A copy of the certification/validation report shall be maintained on file at the validation organization and/or validating laboratory, and shall be available to the public
upon request.
4. A copy of the certification/validation report shall be submitted to OSHA within 30
days of its completion.
D. Publications System
The validation organization shall make
available upon request a list of PSDI safety
systems which have been certified/validated
by the program.
E. Follow-up Activities
1. The validation organization or validating laboratory shall have a follow-up system for inspecting or testing manufacturer’s
production of design certified/validated PSDI
safety system components and subassemblies
where deemed appropriate by the validation
organization.
2. The validation organization shall notify
the appropriate product manufacturer(s) of
any reports from employers of point of operation injuries which occur while a press is
operated in a PSDI mode.
F. Records
The validation organization or validating
laboratory shall maintain a record of each
certification/validation of a PSDI safety system, including manufacturer and/or employer certification documentation, test and

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§ 1910.217

29 CFR Ch. XVII (7–1–09 Edition)

working data, test report, certification/validation report, any follow-up inspections or
testing, and reports of equipment failures,
any reports of accidents involving the equipment, and any other pertinent information.
These records shall be available for inspection by OSHA and OSHA State Plan offices.
G. Dispute Resolution Procedures
1. The validation organization shall have a
reasonable written procedure for acknowledging and processing appeals or complaints
from program participants (manufacturers,
producers, suppliers, vendors and employers)
as well as other interested parties (employees or their representatives, safety personnel, government agencies, etc.), concerning certification or validation.
2. The validation organization may charge
any complainant the reasonable charge for
repeating tests needed for the resolution of
disputes.

3. Pneumatic Systems
Elevated clutch/brake air pressure results
in longer stopping time. The requirement in
paragraph (h)(3)(i)(C) is intended to prevent
degradation in stoping speed from higher air
pressure. Higher pressures may be permitted,
however, to increase clutch torque to free
‘‘jammed’’ dies, provided positive measures
are provided to prevent the higher pressure
at other times.
4. Flywheels and Bearings

APPENDIX D TO § 1910.217—NONMANDATORY
SUPPLEMENTARY INFORMATION
This appendix provides nonmandatory supplementary information and guidelines to
assist in the understanding and use of 29 CFR
1910.217(h) to allow presence sensing device
initiation (PSDI) of mechanical power presses. Although this appendix as such is not
mandatory, it references sections and requirements which are made mandatory by
other parts of the PSDI standard and appendices.
1. General
OSHA intends that PSDI continue to be
prohibited where present state-of-the-art
technology will not allow it to be done safely. Only part revolution type mechanical
power presses are approved for PSDI. Similarly, only presses with a configuration such
that a person’s body cannot completely enter
the bed area are approved for PSDI.

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of significantly increased stopping time if a
spring breaks.
As an added precaution to the requirements in paragraph (h)(2)(iii), brake adjustment locking means should be secured.
Where brake springs are externally accessible, lock nuts or other means may be provided to reduce the possibility of backing off
of the compression nut which holds the
springs in place.

Lubrication of bearings is considered the
single greatest deterrent to their failure.
The manufacturer’s recommended procedures for maintenance and inspection should
be closely followed.
5. Brake Monitoring
The approval of brake monitor adjustments, as required in paragraph (h)(5)(ii), is
not considered a recertification, and does not
necessarily involve an on-site inspection by
a representative of the validation organization. It is expected that the brake monitor
adjustment normally could be evaluated on
the basis of the effect on the safety system
certification/validation documentation retained by the validation organization.
Use of a brake monitor does not eliminate
the need for periodic brake inspection and
maintenance to reduce the possibility of catastrophic failures.

2. Brake and Clutch

6. Cycle Control and Control Systems

Flexible steel band brakes do not possess a
long-term reliability against structural failure as compared to other types of brakes,
and therefore are not acceptable on presses
used in the PSDI mode of operation.
Fast and consistent stopping times are important to safety for the PSDI mode of operation. Consistency of braking action is enhanced by high brake torque. The requirement in paragraph (h)(2)(ii) defines a high
torque capability which should ensure fast
and consistent stopping times.
Brake design parameters important to
PSDI are high torque, low moment of inertia, low air volume (if pneumatic) mechanisms, non-interleaving engagement springs,
and structural integrity which is enhanced
by
over-design.
The
requirement
in
paragrpah (h)(2)(iii) reduces the possibility

The PSDI set-up/reset means required by
paragraph (h)(6)(iv) may be initiated by the
actuation of a special momentary pushbutton or by the actuation of a special momentary pushbutton and the initiation of a
first stroke with two hand controls.
It would normally be preferable to limit
the adjustment of the time required in paragraph (h)(6)(vi) to a maximum of 15 seconds.
However, where an operator must do many
operations outside the press, such as lubricating, trimming, deburring, etc., a longer
interval up to 30 seconds is permitted.
When a press is equipped for PSDI operation, it is recommended that the presence
sensing device be active as a guarding device
in other production modes. This should enhance the reliability of the device and ensure
that it remains operable.

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Occupational Safety and Health Admin., Labor
An acceptable method for interlocking
supplemental guards as required by paragraph (h)(6)(xiii) would be to incorporate the
supplemental guard and the PSDI presence
sensing device into a hinged arrangement in
which the alignment of the presence sensing
device serves, in effect, as the interlock. If
the supplemental guards are moved, the
presence sensing device would become misaligned and the press control would be deactivated. No extra microswitches or interlocking sensors would be required.
Paragraph (h)(6)(xv) of the standard requires that the control system have provisions for an ‘‘inch’’ operating means; that
die-setting not be done in the PSDI mode;
and that production not be done in the
‘‘inch’’ mode. It should be noted that the
sensing device would be by-passed in the
‘‘inch’’ mode. For that reason, the prohibitions against die-setting in the PSDI mode,
and against production in the ‘‘inch’’ mode
are cited to emphasize that ‘‘inch’’ operation
is of reduced safety and is not compatible
with PSDI or other production modes.
7. Environmental Requirements
It is the intent of paragraph (h)(7) that
control components be provided with inherent design protection against operating
stresses and environmental factors affecting
safety and reliability.

tion in the sensing field. A minimum object
sensitivity of one and one-fourth inches
(31.75 mm) means that a one and one-fourth
inch (31.75 mm) diameter object will be continuously detected at all locations in the
sensing field.
In deriving the safety distance required in
paragraph (h)(9)(v), all stopping time measurements should be made with clutch/brake
air pressure regulated to the press manufacturer’s recommended value for full clutch
torque capability. The stopping time measurements should be made with the heaviest
upper die that is planned for use in the press.
If the press has a slide counterbalance system, it is important that the counterbalance
be adjusted correctly for upper die weight according to the manufacturer’s instructions.
While the brake monitor setting is based on
the stopping time it actually measures, i.e.,
the normal stopping time at the top of the
stroke, it is important that the safety distance be computed from the longest stopping
time measured at any of the indicated three
downstroke stopping positions listed in the
explanation of Ts. The use in the formula of
twice the stopping time increase, Tm, allowed by the brake monitor for brake wear
allows for greater increases in the downstroke stopping time than occur in normal
stopping time at the top of the stroke.
10. Inspection and Maintenance. [Reserved]

8. Safety system
The safety system provision continues the
concept of paragraph (b)(13) that the probability of two independent failures in the
length of time required to make one press
cycle is so remote as to be a negligible risk
factor in the total array of equipment and
human factors. The emphasis is on an integrated total system including all elements
affecting point of operation safety.
It should be noted that this does not require redundancy for press components such
as structural elements, clutch/brake mechanisms, plates, etc., for which adequate reliability may be achieved by proper design,
maintenance, and inspection.
9. Safeguarding the Point of Operation

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§ 1910.218

The intent of paragraph (h)(9)(iii) is to prohibit use of mirrors to ‘‘bend’’ a single light
curtain sensing field around corners to cover
more than one side of a press. This prohibition is needed to increase the reliability of
the presence sensing device in initiating a
stroke only when the desired work motion
has been completed.
Object sensitivity describes the capability of
a presence sensing device to detect an object
in the sensing field, expressed as the linear
measurement of the smallest interruption
which can be detected at any point in the
field. Minimum object sensitivity describes
the largest acceptable size of the interrup-

11. Safety System Certification/Validation
Mandatory requirements for certification/
validation of the PSDI safety system are
provided in appendix A and appendix C to
this standard. Nonmandatory supplementary
information and guidelines relating to certification/validation of the PSDI safety system are provided to appendix B to this standard.
[39 FR 32502, June 27, 1974, as amended at 39
FR 41846, Dec. 23, 1974; 40 FR 3982, Jan. 27,
1975; 43 FR 49750, Oct. 24, 1978; 45 FR 8594,
Feb. 8, 1980; 49 FR 18295, Apr. 30, 1984; 51 FR
34561, Sept. 29, 1986; 53 FR 8353, 8358 Mar. 14,
1988; 54 FR 24333, June 7, 1989; 61 FR 9240,
Mar. 7, 1996; 69 FR 31882, June 8, 2004]

§ 1910.218

Forging machines.

(a) General requirements—(1) Use of
lead. The safety requirements of this
subparagraph apply to lead casts or
other use of lead in the forge shop or
die shop.
(i) Thermostatic control of heating
elements shall be provided to maintain
proper melting temperature and prevent overheating.
(ii) Fixed or permanent lead pot installations shall be exhausted.

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File Typeapplication/pdf
File TitleDocument
SubjectExtracted Pages
AuthorU.S. Government Printing Office
File Modified2010-05-17
File Created2009-11-04

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