Machine guarding requirements

Under 1910.212(a)(1) you must use one or more effective guarding methods such as barrier guards, two-hand tripping devices, or electronic safety devices to protect operators from point-of-operation, ingoing nip points, rotating parts, flying chips, and sparks. See the Types of guarding described in 1910.212(a)(1).

• Use whichever method (or combination) actually prevents body parts or clothing from reaching the danger zone during operation.
• Where a specific machine standard exists, the guard must conform to that standard as required by 1910.212(a)(3)(ii).

Under 1910.212(a)(2) guards must be affixed to the machine where possible, and if that is not possible they must be secured elsewhere so they remain effective. See the General requirements for machine guards in 1910.212(a)(2).

• If attachment to the machine would interfere with safe operation or maintenance, provide a secure alternative mounting so the guard cannot be easily removed or displaced.
• Ensure any alternative mounting does not create a new hazard; guards must not themselves present an accident hazard under 1910.212(a)(3).

Under 1910.212(a)(3)(ii) the point of operation must be guarded whenever machine operation exposes an employee to injury, and the guard must prevent any part of the operator’s body from entering the danger zone during the operating cycle. See the Point of operation guarding requirement in 1910.212(a)(3)(ii).

• Where applicable, use guarding that conforms to a specific machine standard; otherwise design guards to physically prevent access to the danger zone for the full cycle of machine motion.
• Special handling tools may supplement guarding but cannot replace required guards per 1910.212(a)(3)(iv).

Under 1910.212(a)(3)(i) the point of operation is the area on a machine where work is actually performed on the material being processed. See the definition in 1910.212(a)(3)(i).

• Identify this area when you assess guarding needs because guards must prevent access to that specific zone during operation.
• Use the definition to determine where fixed guards, interlocks, or other devices must be located to keep operators safe.

Under 1910.212(a)(3)(iii) specially designed handtools can be used to let operators place and remove material without placing their hands in the danger zone, but those tools may only supplement—not replace—required guards. See 1910.212(a)(3)(iii) and 1910.212(a)(3)(iv).

• Use special tools where guards would make feeding or removing workpiece impractical, but still provide guards whenever the operation exposes employees to injury.
• Document and train workers on correct use of such tools so they effectively reduce exposure.

Under 1910.212(a)(3)(iv) machines that usually require point-of-operation guarding include guillotine cutters, shears, alligator shears, power presses, milling machines, power saws, jointers, portable power tools, and forming rolls and calenders. See the list in 1910.212(a)(3)(iv).

• Treat the listed machines as high priority for guarding during hazard assessments.
• When in doubt, follow the standard’s requirement to prevent operator body parts from entering the danger zone during operation per 1910.212(a)(3)(ii).

Under 1910.212(a)(4) revolving drums, barrels, and containers must be enclosed by an interlocked guard so they cannot revolve unless the enclosure is in place. See the Barrels, containers, and drums requirement in 1910.212(a)(4).

• Use an interlock that prevents drive power from engaging if the enclosure is open or removed.
• Maintain the interlock and test it regularly so the enclosure reliably prevents rotation when workers could access the drum.

Under 1910.212(a)(5) fan blades must be guarded when the blade periphery is less than seven feet above the floor or working level. See the Exposure of blades requirement in 1910.212(a)(5).

• Measure the seven-foot threshold from the floor or the primary working surface where employees stand or walk.
• Ensure guards prevent contact with the blade and do not create new hazards per the general guard safety requirement in 1910.212(a)(3).

Under 1910.212(a)(3) a guard must not create an accident hazard itself, so guards should have no sharp edges, pinch points, or obstruct escape routes and must be strong and secure. See the requirement that guards not offer accident hazards in 1910.212(a)(3).

• Inspect guards for burrs, protrusions, or openings that could snag clothing or cause cuts.
• Make sure guards are secured and cannot fall into machine parts or be dislodged easily, consistent with the affixation rule in 1910.212(a)(2).

Under 1910.212 you may temporarily remove guards when power is required for testing or positioning, but you must follow procedures that protect employees during re-energization—clearing tools, removing employees from the danger area, and using effective protections while energized. See 1910.212(a) together with OSHA’s Lockout/Tagout guidance in the Minor servicing exception clarification letter.

• Follow the sequence in the LOTO interpretation: clear tools/materials, remove employees, remove LOTO devices per the procedure, energize only for the brief testing or positioning interval, then de-energize and reapply controls if more servicing is required.
• Provide guarding or other protective measures (e.g., barriers, procedures) during energized testing so workers cannot reach danger zones.

Under 1910.212(a)(2) if a guard cannot be affixed to the machine and is secured elsewhere, document how and where it is mounted, why attachment is not possible, and maintain inspection and maintenance records showing the guard remains effective. See the affixation requirement in 1910.212(a)(2).

• Keep records of periodic inspections and repairs so you can show the guard remains secure and functional.
• Train operators and maintenance staff on correct installation/removal procedures for guards that are not machine-mounted.

Under 1910.212(a)(3)(iv)(h) (portable power tools) are included among machines that usually require point-of-operation guarding, so provide guards or other protective measures to prevent contact with rotating or cutting parts. See 1910.212(a)(3)(iv)(h).

• Use guards, tool guards, or jigs that keep hands away from blades and rotating bits, and ensure guards do not interfere with safe operation.
• Train users on safe handling and require appropriate PPE when guards cannot fully eliminate exposure.

Under 1910.212(a)(4) enclosures for revolving drums, barrels, and containers must be interlocked with the drive so the container cannot revolve unless the enclosure is in place—an example is an interlocked access door that disables the motor when opened. See 1910.212(a)(4).

• Design interlocks so they cannot be easily bypassed and test them after maintenance.
• Document interlock function and test frequency in your preventive maintenance records to show compliance.

Under 1910.212(a)(3)(ii) employers should identify the point of operation and determine the full range of motion and areas where parts or material could strike or pull in a person, then design guards to prevent any body part from reaching that danger zone during the operating cycle. See 1910.212(a)(3)(i)–(ii).

• Observe the machine in all modes (startup, normal run, jog/inching) and map where contact could occur.
• Use physical measurements and reach-distance tables when selecting barrier size, or rely on interlocks/light curtains where fixed barriers are impractical.

Under 1910.212 guards should not be removed during normal production; if a changeover requires temporary re-energization or special access, follow the procedures in the LOTO guidance that allow brief removal for testing or repositioning while maintaining employee protection. See 1910.212(a) and the Minor servicing exception clarification letter.

• If the work is service/maintenance (not normal production) and cannot be done without power, use the specific sequence for temporary re-energization in the LOTO guidance and provide alternative protective measures during energization.
• Do not use the temporary exception to avoid full LOTO requirements during the bulk of servicing work.

Under 1910.212(a)(3)(iv)(i) forming rolls and calenders are listed as machines that usually require point-of-operation guarding because they present severe ingoing nip and crushing hazards. See 1910.212(a)(3)(iv)(i).

• Provide guards or devices that prevent fingers, hands, or clothing from being drawn into nip points.
• Consider interlocks, trip devices, or guarded feed rolls to keep operators safe during operation.

Under 1910.212(a)(1) employers must provide guarding methods (such as barrier guards, enclosures, or screens) to protect operators and other employees from flying chips and sparks generated by machine operation. See the Types of guarding in 1910.212(a)(1).

• Use shields or full enclosures to confine chips and sparks, and provide eye protection as a supplemental measure.
• Position workstations and shields so bystanders are not in the trajectory path of ejected material.

Under 1910.212(a)(3)(iv)(d) power presses usually require point-of-operation guarding, so employers must install appropriate guards or devices that physically prevent access to the die area during the press stroke. See 1910.212(a)(3)(iv)(d).

• Consider presence-sensing devices, two-hand controls, interlocked guards, or fixed barriers based on the press type and operation, and follow any specific standards applicable to presses.
• Ensure any device used prevents the operator from placing a hand in the danger zone at any point during the operating cycle, consistent with 1910.212(a)(3)(ii).

Under 1910.212 employers must maintain guards so they remain effective and inspect them regularly; keep records of inspections, repairs, and training to demonstrate ongoing compliance. See 1910.212(a)(2) and the general point-of-operation obligations in 1910.212(a)(3)(ii).

• Document periodic guard inspections, corrective actions, and any tests of interlocks or safety devices.
• Train operators and maintenance staff on inspection frequency and the procedure for removing and reinstalling guards safely.

Under 1910.212(a)(1) electronic safety devices (like light curtains or presence-sensing systems) may be used as one method of guarding provided they reliably prevent access to the danger zone and are appropriate for the machine and task. See the Types of guarding in 1910.212(a)(1).

• Validate that the device’s response time and detection field actually protect employees for the machine’s speed and motion; if no specific consensus standard applies, design protection to prevent any body part from entering the hazard during the operating cycle per 1910.212(a)(3)(ii).
• Maintain and test electronic devices on a scheduled basis and document tests and repairs to ensure continued effectiveness.

Under 1910.212, machine guarding addresses physical access hazards, but when other hazards exist—such as aggregated hazardous chemicals or flammable gases—employers must also consult the applicable process or chemical safety standards (for example, OSHA’s Process Safety Management standard) and related interpretations. See 1910.212 and OSHA’s PSM interpretation on flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

• If your operation includes storage or on-site quantities of hazardous chemicals that reach PSM thresholds, follow 29 CFR 1910.119 and the associated interpretations.
• Integrate guarding, ventilation, and chemical hazard controls so all risks are addressed together.