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Machine Guarding OSHA requirements...

Machine Guarding OSHA requirements...

(OP)
thread283-394070: Add Emergency Stop Button to old machinery (machne tools)
In reference to the year-old question, my professional opinion as a CSP consultant is the following: OSHA requirements are legal, not moral or ethical standards. On the other hand, the failure to comply with community standards or to observe due diligence or best practice, beyond the legal requirements, might expose the person or business to undesirable liability risk.

OSHA requirements originated from the ANSI B series of machine guarding when OSHA was formed in 1970-71. Beyond the limited text of the standards at 29 CFR 1910.212 through 219, OSHA also incorporated by reference ANSI standards related to safeguarding grinders, power transmission (belts, sprockets, chains, etc.), and conveyors. These ANSI Stds are: a) ANSI B7.1-70 (grinders), b) ANSI B15.1-53 (R 58) (belts, sprockets, etc.), and c) ANSI B20.1-57 Safety Code for Conveyors, etc.

Neither the OSHA regulatory text nor the consensus standards incorporated by reference require the use of stop emergency buttons, or one-handed/two-handed controls of machinery or equipment.

OSHA enforces these requirements through one of three ways: a) The general machine guarding requirement at 1910.212(a)(1), where various methods of protection are suggested, including but not limited to buttons, to protect from "from hazards such as those created by point of operation, in-going nip points, rotating parts, flying chips and sparks"; b) for the point of operation guarding only, 1910.212(a)(3)(ii), which requires guarding conforming to "any appropriate standards" or otherwise effective; c) for other types of hazards or machinery, OSHA would apply the general duty clause Sec 5(a)(1) of the Act, having to show a recognized serious hazard and a feasible means of abatement, usually by referencing ANSI, NFPA, NEC, ASME, ASHRAE, and even ACGIH.

Age of the equipment WILL not preempt a violation of machine guarding standards subject to one of these regulatory tools. There are a lot of machine-guarding guides that will help with most applications. For more complicated requirements, many outfits who specialize in machine guarding or a knowledgeable consultant would be able to assist.

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