Machine Tool Guarding and OSHA Compliance

Just because your Grandfather could have used it

doesn’t mean OSHA ‘grandfathered’ it.

Machine tool safety is paramount in any industrial setting.   One common misconception is that older tools, often deemed as “grandfathered,” are exempt from current safety standards.  This blog will debunk that myth and provide essential guidelines for maintaining and assessing the safety of both old and new machinery and tools.

The Myth of Grandfathering

Many believe that older machinery and tools, because they were safe to use during their initial production period, are automatically exempt from current OSHA standards.  This is not the case. OSHA does not “grandfather” old machinery and tools; instead, it holds employers accountable for ensuring all equipment meets contemporary safety requirements.

OSHA’s General Requirements for Machine Guards

According to OSHA, machine guards must meet the following general requirements to protect workers from dangerous moving parts:

• Prevent Contact:  Guards must prevent workers’ hands, arms, or other body parts from touching moving parts.
• Be Secure:  Guards must be firmly attached to the machine or secured elsewhere, and workers shouldn’t be able to easily remove or tamper with them. Guards and safety devices should be made of durable materials that can withstand normal use.
• Create No New Hazards:  Guards shouldn’t introduce new hazards, and they should allow for lubrication while still in place.
• Machine Operation Without Interference:  Guards shouldn’t interfere with how the machine operates.

Guards should also be free of sharp edges, burrs, slag welds (hardened layers of nonmetallic material that form on top of welds during some arc welding processes), fasteners, or other hazards that could injure people when handling, removing, or using them.  Handles on guards should be secured so they don’t create pinch points between the handles and the guard, frame, or machine.  The design of the guard should also ensure that people can’t reach the hazard by reaching over, under, around, or through it.

Specific Requirements for Machine Guarding

• Rotating Parts:  Rotating parts that are 7 feet or less above working surfaces, such as gears, sprockets, and chains, must be guarded to prevent employee contact.
• Point of Operation Guarding:  This type of guarding can use barrier guards, two-hand tripping devices, electronic safety devices, or other devices. Machines that often require point of operation guarding include guillotine cutters, shears, power presses, milling machines, power saws, jointers, portable power tools, and more.

Employer Responsibilities

1. Regular Assessment and Maintenance:
   • Employers are responsible for the continuous assessment and maintenance of machine and tool safety, regardless of the machinery or tool’s age.
   • Safety must be evaluated against current OSHA requirements and industry standards such as the National Fire Protection Association (NFPA) and the American National Standards Institute (ANSI).
2. Stop Switches:
   • Must be within reach of the operator.
   • Must be red.
   • Only the stop function may be marked in red to avoid confusion.
3. Protection from Hazards:
   • Operators must be protected from swarf (fine chips or filings of stone, metal, or other material produced by a machining operation) and debris.
   • Rotating parts such as chucks must be adequately guarded.  (A chuck is a specialized type of clamp used to hold an object with radial symmetry, especially a cylinder. In a drill, a mill and a transmission, a chuck holds the rotating tool; in a lathe, it holds the rotating workpiece)
   • Machines should not automatically restart after power disruptions without operator intervention.

Addressing Misconceptions

• Old Machinery & Tools:  Machinery and tools that predate OSHA’s regulations are not automatically compliant. Employers must ensure these machines and tools are updated to meet current safety standards.
• New Machinery & Tools:  Do not assume new machinery and tools are compliant right out of the box. Manufacturers might sell machines and tools without necessary guards, making it imperative to validate safety features upon acquisition.

Best Practices for Safety Compliance

1. Retain Manuals:
   • Keep all equipment manuals for reference upon purchase.  They are essential for understanding the proper use and maintenance of the machine or tool.
2. Validate Guarding:
   • Ensure guarding features are checked and validated when new equipment is acquired.
3. Maintain Guards:
   • Ensure that guards are not removed or altered.
   • Regularly inspect guards for damage and functionality.
4. Review Standards:
   • Periodically review and update safety protocols to align with current industry standards.
5. Auction Purchases:
   • Determine the necessary guarding for machinery and tools purchased at auctions.
   • Research and factor in the additional costs for adding the required guards to ensure compliance.

Ensuring machine tool safety is an ongoing process that involves regular assessment, maintenance, and adherence to current standards. Implement these best practices to maintain an effective safety program and comply with OSHA regulations effortlessly.

Contact us today to learn more about how we can assist with your machine tool assessments and provide the best resolutions for your safety and compliance needs.  Let our expert team help you ensure a safer and more efficient workplace.

Article co-written by:

Alistair Paget, NRP, Certified Safety Professional (CSP) and Professional Member of the American Society of Safety Engineers

Anna Hamilton, RN, BSN MS, COHN/SM, Occupational Health and Safety Consultant