Rules for hiring an apprentice


I am a sole proprietor and an owner of a small table top Kelsey 5x8 and a C&P 10x15. I was approached by a gal at our local Wayzgoose event and she was inquiring about an apprenticeship. I like the idea, but am wondering about the legality of it. I don’t want to be foolish and then get into legal trouble.

Any light you can shed would be super helpful!!
Thanks, Katie

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Well legally, she can’t print on a motorized platen, if you’re in the US. According to OSHA, they can only be ‘owner operated’.


call insurance company.

HavenP is entirely correct that under US OSHA rules you cannot allow an employee to operate a flywheel operated C&P. Many, many of us have fought this battle with OSHA in the past (and discussed it here on Briar Press) As far as I can tell, no-one has ever been granted a waiver to do so. It’s a violation of FAR section 1910…. and they won’t budge on it now matter how you present it to them.

Other agencies have adopted a similar stance regarding letterpresses, and have their own prohibitions about allowing students and the “general public” to operate the machinery.

Technically, if your company is incorporated then even the owner cannot operate the press….since he/she is considered an employee. So, essentially, the only folks who can run a C&P in a business setting is a sole proprietor who owns the press in question.

If you never sell any of your work, then the OSHA rules don’t apply.

BUT all of that being said, the chances of OSHA coming into your shop and hauling you off to jail are pretty remote. The primary risk you run is the possibility of having an accident, and then the injured party suing you for negligence…… against which there is no defence, (“I didn’t know” does not cut it, I’m afraid) and your Work-Comp insurance will probably not cover it.

That is NOT to say you should not take an apprentice. You should. The actual press work is a small part of printing, and you apprentice could learn a lot helping you set type and so forth….. you just can’t legally allow them to operate a flywheel operated C&P press.

I actually own my C&P, even thought he business is inc’d, and I rent it to the corp every year for a penny.

Just kidding. I wasn’t aware of that technicality but it’s interesting. Maybe if I hurt myself on it I can file suit against my…. self.

hhmmm I never thought of that! You might make some money that way!

Actually, i think it’s a good example of Beaurocracy run amuck… and/or a government over-reach. It ranks right up there with motorcycle helmet laws and NYC’s ban on Big Gulps.

BUT hey, I’m just one of those nuts who still believe in freedom and personal responsibility.

Alright, one last post before going back to my soul-crushing deadlines:

On one of my presses, I have a “Reliance Platen Guard” which I think was manufactured by C&P (I’ll post some photos when I have a chance). It was a 1/4” rounded rectangle wrapped in canvas that was designed to push out a hand as the press went into impression.

My dearly-departed father bought this press just because it had this device.

I called my friend Gerald Beiler about this device, and if I remember right he said he’s never even heard of it (or maybe he’s never seen one, I don’t remember).

Has anyone else heard of this device? I only have it on one of my presses, and have never seen it anywhere else. I’ve wanted to post photos here for a while, but keep forgetting to.

Also, on the same press, there’s a guard that covers the whole flywheel to prevent someone sticking their hands or feet in it.

Can any surmise if this would be ok under OSHA?

Just throwing it out there.

I’ve only seen these guards on presses taken from schools.
I did a quick look at the OSHA website for more information; OSHA does not make any reference to letterpress, though for other printing processes, amputation is a primary concern. Any cycling hand-fed platen has so many pinch points and incoming nips that it couldn’t be made OSHA safe with just a platen guard.
Some European platens will stop the press if there is anything between a hanging guard and the top of the platen as it closes, but that utilizes a clutched flywheel, and a start-stop lever where the C&P has an impression throw-off. But there’s no reason a engineer couldn’t retrofit a mechanical brake to the flywheel of a C&P to be triggered by European-style hanging guard. To guard all the other danger points you’d end up with a box like the C&P Model N.

The guards were once pretty common and made by several manufacturers, including an insurance company. I’ve seen a few over the years and ran a press once with one. And Eric’s point about box like enclosures are evidenced by late model Kluges in their effort to make their line of presses bullet proof as far as OSHA is concerned—ease of use is another matter.

The canvas with metal frame guard rose up between the near edge of the platen and the top lip of the delivery board as the platen closed.
I think they probably were devised primarily for school presses.
We did not have them on our 10 x 15 C&Ps in 1947-49 when I learned to print in school.
It is my understanding that in any/many shops presses came to with these guards, the pressman took them off.
I am speculating, but I doubt OSHA would find them as a satisfactory safety solution.
I think Kluge stopped supplying parts for their old hand fed presses and advised owners to scrap them. Sad

Kluge set a date, I believe 1962, when they started to enclose the presses with safety enclosures, that they would not support any press made before that date, hand fed or automatic. They advertised this rather heavily in the trade magazines and urged owners of pre-1962 presses to take them out of service and scrap them. I talked to the support people at Kluge about this and they said several lawsuits had almost put them out of business and it was for liability purposes they did this—OSHA didn’t come along until December of 1970 so the blame can’t be put on the federal government. Kluge holds to this policy to this day—ask any Kluge owner who has tried to get parts for an older Kluge. They require a serial number before they will even open a discussion about parts or servicing.

Heidelberg USA also holds to a similar policy on serial numbers—if a Heidelberg press was brought into this country other than through the Heidelberg USA sales then they will not furnish parts. Many letterpress and offset machines were purchased overseas, mainly Europe, and those press owners have to source parts through dealers or anyone but Heidelberg. And this for liability concerns above and beyond OSHA.

I was gifted a n old kluge, didn’t take long to break a part on it, I was fortunate to have a friend who was a kluge salesman, he gave me a mans name and phone number and told me to mention his name, when I gave them the serial number they said they could not sell me the part, he did look up the number and told me my press was made about 1934. Also have a windmill that was bought new from heidleburg before I bought the print shop, the first time I tried to buy parts for it heidleburg told me a had bootleg equipment, they are not someone I would do business with, another time I called them and asked for a price on a gripper, I must have said at least 5 times that I only wanted a price and if I decided to buy one I would call them back, 3 days later I received a package from ups with 2 grippers and it was cod for $1200.00 which was send back,i will only deal with them as a last resort.

How about this windmill on ebay for sale…. Guards all over!

image: 10x15.JPG


Rubicon, That looks like the imitation windmill from Adast called a Graphopress I believe.

Lots of fine words re the vagaries of offering and being asked about apprenticeships, in a trade or calling that used to have a specified time period, with signed off indentures on completion.

Lots of quotes from and regarding OSHA etc, should the question be posed as to who is authorized/empowered/certified to administer an apprenticeship.!!!

Interested to know if there are any Rules in this respect, The Master (as in *Master Printer*) should have some guidelines for mutual benefit, Master & Apprentice both.

Here in the U.K. until the demise of Letterpress Proper Bona Fide apprenticeships were Minimum of 5 years,(or 6 years if one left Tech./College at 15)

Obligatory to have junior Union Affiliation, U.K. T.A. (Typographical Association. — N.G. A (National Graphical Association) etc. In limited form all the benefits of Union protection regarding Pay and Conditions, after year 2/3 got to vote at Chapel Meetings etc.

This in contrast to One or Two unfortunate Buddies/Pals who could only obtain or squeeze in to what we called *RAT SHOPS* i.e. Non Indentured Apprenticeships in very debatable premises, with dodgy Machinery, and take it or leave it Wages.

Good Luck to both would be Apprentices and the Master,s Look after each other and of course, this terrific Medium.
We have lost too much already. Mick.