#10: OSHA’s Machine Guarding Standard Final Sections and Compliance Tips

In this final section of the Machine Guarding series, we will break down and explain sections 1910.212(a)(4), (a)(5), and (b), offering our best suggestions and tools for ensuring compliance.

1910.212(a)(4) – Barrels, Containers, and Drums

Standard Summary: Revolving drums, barrels, and containers must be guarded by an enclosure interlocked with the drive mechanism, preventing revolution unless the guard is in place.

OSHA’s Intent:

• Equip revolving drums, barrels, and containers with interlocked guards that prevent movement when the guard is opened or removed.

Compliance Notes: Safety interlocks is a big discussion with a lot of moving parts (see what we did there?). The critical take aways about interlocks are that they’re not a substitute for lockout/tagout procedures and they require regular testing to ensure proper functionality. Many injuries and citations could have been prevented if companies would have periodically tested their safety interlocks and taken a few extra minutes to actually power down and lock out machinery.

1910.212(a)(5) – Exposure of Blades

Standard Summary: Fan blades less than seven feet above the floor or working level must be guarded with openings no larger than one-half inch.

OSHA’s Intent:

• Guard fan blades either by distance (mounting at least seven feet above the floor) or with physical guards having openings no larger than one-half inch.

Compliance Notes: OSHA introduces the concept of guarding by distance which allows fans to be left unguarded when they are mounted seven feet or higher above the floor or working surface. For fans below this height, the cages or guards protecting workers from the fan blades must not have openings greater than one-half inch wide.

During an inspection, fans can be a beacon for OSHA inspectors. This can include fans being actively used but also the ones sitting in the maintenance shop awaiting repair and any fans sitting in storage. Regardless of their status, it’s always a good idea to include them in regular inspections. A great place to start is to do the following:

• Inventory and number all fans
• Inspect fans regularly (e.g., biannually)
• Discard broken fans
• Tag out non-compliant fans to prevent reuse while awaiting repair

1910.212(b) – Anchoring Fixed Machinery

Standard Summary: Machines designed for a fixed location must be securely anchored to prevent movement during operation.

OSHA’s Intent:

• Anchor fixed machinery to give it some stability and to prevent it from moving or “walking” during use

Compliance Notes: Unanchored machinery is more low-hanging fruit for OSHA, particularly when an inspection is taking place after a reportable incident or fatality. As soon as one piece of machinery that’s not properly secured, it’s going to prompt them to look for others. If they happen to locate additional instances, it’s going to be really easy for them to say there’s an established pattern of noncompliance—all because no one took 15 minutes to secure that bench grinder to the table it’s sitting on.

Compliance Tools and Strategies

For those unsure of how to get started with things, our free machine guarding assessment template is available to address basic requirements. For those currently using the Audit & Inspection module, consider our machine guarding assessment question set which can be imported into the module and used like any other question set.

Machine guarding can seem complex, especially for those new to safety regulations or who haven’t spent much time around machinery. A few ideas for making things a bit simpler and easier to digest are to do the following:

• Try breaking standards down into individual parts and study each one separately
• Research definitions and when available, read OSHA’s letters of interpretation
• Use OSHA’s resources, like their series of interactive tools (apps, checklists, eTools, eAdvisors) and topic pages (like the one on machine guarding) to deepen knowledge
• Conduct thorough workplace inspections and don’t forget to look for that low hanging fruit like unguarding fans and equipment that’s not secured

What’s Next?

The next article in this series will explore 1926.102, Eye and Face Protection, which ranks ninth on OSHA’s top ten most-cited standards list. It will cover the four most frequently cited parts, their meanings, and compliance strategies.

While you wait for our next installment, why not check out what EHS Insight has to offer or even give us a shout? We’d love to talk to you about how we can help with your compliance needs.

To read our full machine guarding standard guide, click here.