#10: OSHA’s Machine Guarding Standard: Part Two

Part two of our machine guarding series will address 1910.212(a)(1) through (a)(3), explaining their requirements and addressing a few typical compliance challenges.

1910.212(a)(1) – Types of Guarding

Standard Summary: One or more guarding methods must be used to protect operators and nearby workers from hazards like the point of operation, ingoing nip points, rotating parts, flying chips, and sparks. Examples include barrier guards, two-hand tripping devices, and electronic safety devices.

OSHA’s Intent:

• Both machine operators and workers in the area must be protected from machine hazards
• The specific hazards in question are from the point of operation, pinch points, rotating parts, and flying sparks and debris
• Appropriate guarding methods such as barrier guards, two-hand tripping devices and electronic safety devices are to be used

Compliance Challenges: Some of the confusion leading to non-compliance comes from terms like “point of operation” and “ingoing nip points.” Unfortunately, OSHA’s Subpart O definitions are somewhat lacking and either omit definitions completely or supply several definitions for the same term, like “point of operation”. To further complicate things, OSHA doesn’t always use uniform terminology for the same concept. Case in point, “ingoing nip points” are also referred to as “in-running nip points” and “pinch points”, which can be confusing for anyone not familiar with machine guarding or who hasn’t spent a lot of time interpreting standards.

Key Definitions:

• Point of Operation: Where the machine performs its work, e.g., where a saw blade cuts material.
• Ingoing Nip Points: Areas where machine parts converge, creating pinch points that can pull in objects or body parts, e.g., rolls on a rolling mill.

Recommendation: When in doubt, OSHA’s machine guarding e-Tool is an excellent resource that among other things, includes animations to help clarify hazardous motions and actions.

1910.212(a)(2) – General Requirements for Machine Guards

Standard Summary: Guards shall be affixed to the machine where possible and secured elsewhere if for any reason attachment to the machine is not possible. The guard shall be such that it does not offer an accident hazard in itself.

OSHA’s Intent:

• Attach guards directly to machines when possible
• When not possible, secure guards elsewhere
• Whatever guards are used, make sure they are safe and do not introduce new hazards

A great way of understanding this is to think about it as a process:

1. Identify the point of operation, ingoing nip points, rotating parts, and the sources of any debris and/or flying sparks
2. Observe worker interaction with unpowered machinery to understand how operators interact with that machinery
3. Select guarding methods to protect workers based on identified hazards
4. Determine if guards can be affixed to the machine; if not, secure them nearby
5. Evaluate guards to ensure they are not easily defeated and do not create new hazards

Compliance Considerations:

• Easily Defeated Guards: Barrier guards must be secured with tamper-proof screws or specialty fasteners to prevent easy removal or bypassing.
• New Hazards: Guards must not introduce risks like trip hazards, jagged edges, shear points, or electrical hazards.

1910.212(a)(3) – Point of Operation Guarding

Standard Summary:

• (a)(3)(i): Defines the point of operation as the area where work is performed on whatever material is being processed
• (a)(3)(ii): Requires guarding for points of operation that pose injury risks, conforming to relevant standards or designed to prevent body parts from entering the danger zone during operation
• (a)(3)(iii): Permits special handtools to avoid hand (or other body part) placement in the danger zone, as a supplement to not a replacement for, other guarding

OSHA’s Intent:

• The point of operation must be identified and guarded
• Guarding used must be compliant with appropriate standards
• Where there aren’t specific standards, guarding must prevent workers from placing any body parts in the danger zone during the operating cycle
• Allows for special handtools to move material into and out of the point of operation but not by themselves or in lieu of machine guarding

Compliance Challenges:

• Employers may focus solely on attaching guards to machinery, overlooking 1910.212(a)(2)’s allowance for securing guards elsewhere when attachment is not possible
• Not considering the machinery’s use environment. For example, a miter saw’s self-adjusting blade guard may be insufficient in a distracting environment, requiring additional controls like two-hand trip devices and pneumatic foot pedal controls
• The use of special handtools as primary guarding rather than installing proper and affixed guards
• When accessing the danger zone of machinery allowing workers to rely on safety interlocks and special handtools rather than employing federal lockout/tagout standards as required (see 1910.333(b)(2)(ii)(B)).

Additional Notes: Section (a)(3)(iv) lists nine machine types typically requiring point of operation guarding, but this is not exhaustive. All machinery, regardless of whether it appears by name in this part of the standard should be assessed for guarding needs.

By understanding and applying 1910.212’s requirements, employers can address hazards, reduce OSHA citations, and enhance workplace safety.

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