OSHA 1910.212 – Standards for Machine Guarding and General Safety Guidelines
“Employee safety is the first priority overall, not just a tagline, so everyone returns back to their families every day as they left them. PowerSafe Automation’s mission is to provide a safer working environment for team members through innovative engineered solutions while relying less on administrative policy controls or exceptions.” Learn more about PowerSafe Automation at www.powersafeautomation.com
By: Shawn Mantel, Contributor
One of the most common phrases in the manufacturing industry is “safety is everyone’s responsibility.” This certainly is a valid point, but safety must start with machine guarding, as it is the first line of defense. Workers need to be provided with the proper tools helping them to avoid hazards such as pinch, cut, shear and crush points. Beyond it being the right thing to do, by law, it’s a company’s responsibility to provide a safe work environment under OSHA 1910.212.
About the Regulation
OSHA 1910.212 states that one or more methods of machine guarding must be provided to protect the operator and other employees in the machine area from hazards created by the point of operation, such as ingoing nip points, rotating parts, flying chips and sparks. Machine guards must be affixed to a machine, and the guard cannot be an accident hazard in itself.
Due to the number of distractions, increased fatigue from manpower issues, lack of experience, and tighter machine placements in the workplace, keeping out of harm’s way should not be left up to chance by human decisions.
Engineering out the safety hazards such as pinch, shear, burn, crush, or cut points with ANSI B11 standards mostly related to reach over, reach through, or crawl under along with best practices, greatly improves the ability to mitigate the hazards through technologies.
To comply with OSHA 1910.212, it is recommended that you seek out a turnkey machine safety company with the experience to help evaluate, design, build, install and integrate numerous types of guarding including point guarding, perimeter guarding, power transmission covers, machine tool shields and presence sensing devices. Machine guarding is in the top 10 list of most-cited OSHA violations – an indication that failing to follow the guidelines of this regulation could lead to injury, death, fines, litigation and more.
Machines are an inanimate object … no brains, no feelings, no common sense, no voice to warn workers about hazards, only built-in operator intelligence. By the time the machine has let you know there is a problem, it is usually too late. So, you need to minimize some of these characteristics in the human thought process as well. The investment of proactively putting the proper machine guarding in place more than outweighs the costs associated with a reactive approach of doing nothing.
Enforcement Activity
Citations regarding this standard by Federal OSHA inspections during the period October 2022 through September 2023:
Other Provisions
- The point of operation — the area on a machine where work is actually performed upon the material being processed — shall be guarded. The guarding device must be designed and constructed as to prevent the operator from having any part of his body in the danger zone during the operating cycle.
- Machines which usually require machine guarding include: guillotine cutters, shears, alligator shears, power presses, milling machines, power saws, jointers, portable power tools, forming rolls and calenders.
- Revolving drums, barrels, and containers shall be guarded by an enclosure which is interlocked with the drive mechanism, so that the barrel, drum, or container cannot revolve unless the guard enclosure is in place.
- When the periphery of the blades of a fan is less than 7 feet above the floor or working level, the blades shall be guarded. The guard shall have openings no larger than one-half inch.
- Machines designed for a fixed location shall be securely anchored to prevent walking or moving.
Types of Machine Guarding
There are a lot of different types of engineered solutions for machine guarding options, such as modular machine guarding, consumer products guarding, robotic safety guarding, palletizing safety systems, industrial sound enclosures, hazardous chemical containment enclosures and power transmission guards which minimizes the need for admin controls. In addition to the physical guarding, adding electronic safety devices brings the guarding to life by intelligently interacting with the machine control functions. It is critical to make sure you choose the appropriate guarding that fits your processes, production, and maintenance for your type of equipment as well as choosing the right turnkey solutions contractor to ensure proper design, installation, and electrical integration of the guarding.
“I have been doing it that way for 20 years,” “the machine came that way,” “no one would stick their hands in there,” “no one should be back there,” are all objections from workers for not being accepting of the guarding. This is one of the reasons the solutions should not be cumbersome, or they should at least minimize the effects safety has on production rates. The solution should not create opportunities for employees to attempt a bypass or work around, and should allow them to interact with the machine properly, regardless of its age.
Custom fixtures, no touch tools and automation levels must also be considered in conjunction with the machine guarding. OSHA was not formed until the mid 70s, so legacy machines were not built with much safety in mind. Those machines must be properly guarded, although it may be necessary to upgrade them in order to implement modern guarding techniques. This could include part shuttles, positioning sensors, vision or camera viewing systems, pick and place units, dynamic braking systems, and part hold down or nesting fixtures. Finding a company that focuses on machine safety and automation as a potential combined package can be beneficial to the upgrading of machine safety, depending on the age of your machine.
While the focus is on machine guarding you must complete the process by creating systems, controlled processes, training programs, and routine audits of your controls and the guarding for better success with your machine safety directives. Consequences should also be put in place in case these guidelines are not followed. Emphasize that safety is everyone’s responsibility. Instead of being an overhead expense, machine guarding is an investment in keeping your workers safe.
View the regulation at: www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.212 WMHS
Shawn Mantel is the CEO and sales engineer at PowerSafe Automation, a leading provider of turnkey machine safety guarding and industrial automation solutions. PowerSafe Automation specializes in custom design, fabrication, assembly, and nationwide installation services including electronic integration — unique services that help customers reduce hazards, improve workplace safety and minimize downtime. To learn more about PowerSafe Automation’s innovative solutions and commitment to meeting compliance and OSHA regulations, visit www.powersafeautomation.com.