The Occupational Safety and Health Administration (OSHA) and state worker protection agencies require employers to “guard” moving portions of machines and powered equipment, to prevent entanglements, pinches and amputations. OSHA sets general requirements for machine guarding under its Machine Guarding Standard, plus specific requirements for six different types of equipment in separate standards.
Which Hazards Must Be Guarded, And How?
OSHA’s Machine Guarding Standard applies to operations that create the following types of hazards:
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“Point of operation” hazards created at a point where cutting, shaping, boring, or forming of materials takes place
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Hazards presented by drill bits and other “nip points” entering into materials
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Hazards from rotating parts
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Hazards from flying chips and sparks.
OSHA provides examples of machines that usually require point of operation guarding: guillotine cutters; shears; alligator shears; power presses; milling machines; power saws; jointers; portable power tools (including heavy-duty portable pneumatic powered staplers and nailers); and forming rolls and calendars.
Employers with hazardous machinery must apply one or more methods of machine guarding to protect the operator and other employees during operations. OSHA provides the following examples of guarding methods, although employers may use others:
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Barrier guards—devices that physically block access to hazards.
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Two-hand tripping devices—equipment that requires simultaneous, positive action with two hands to operate.
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Electronic safety devices—designed to detect obstructions and shut down equipment.
The guarding device must be designed and constructed to prevent the operator from having any body part in the dangerous operating zone during work. Accordingly, “awareness guarding” such as a chain equipped with a warning sign does not meet these requirements, since it does not prevent physical contact.
OSHA places two general design requirements on machine guards:
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Guards must be attached in one of the following ways:
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Affixed to the machine itself where possible
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Secured to other nearby equipment, or elsewhere if necessary
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A guard must not create an accident hazard in itself
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Woodworking machinery
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Abrasive wheel machinery
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Mills and calendars for rubber and plastics
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Mechanical power presses
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Forging machines
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Mechanical power transmission apparatus
An employer that has one of these specific types of machinery must meet applicable requirements – employers with other types of hazardous machinery can inform their compliance activities by comparison with analogous requirements for other types of machinery.
Self-Assessment Checklist
Do any of the organization’s activities include machinery with moving portions that may create risks of entanglements, pinches or amputations?
If so, has the organization installed safeguards to protect against those hazards:
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Do the safeguards provided meet the minimum OSHA requirements?
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Do the safeguards prevent workers’ hands, arms, and other body parts from making contact with dangerous moving parts?
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Are the safeguards firmly secured and not easily removable?
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Do the safeguards ensure that no objects will fall into the moving parts?
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Do the safeguards permit safe, comfortable, and relatively easy operation of the machine?
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Can the machine be oiled without removing the safeguard?
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Is there a system for shutting down the machinery and locking/tagging out before safeguards are removed?
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Can the existing safeguards be improved?
Where Do I Go For More Information?
Information available via the Internet includes:
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OSHA safety and health topic webpage for machine guarding
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OSHA National Emphasis Program on Amputations
Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:
About the Author
Jon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.
Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).
Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).
You may contact Mr. Elliott directly at: tei@ix.netcom.com
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