February 13, 1981
MEMORANDUM FOR: DONALD E. MACKENZIE
THRU: JOHN MILES
ACTING FIELD COORDINATOR
FROM: BRUCE HILLENBRAND
ACTING DIRECTOR, FEDERAL COMPLIANCE
AND STATE PROGRAMS
SUBJECT: National Policy on Guarding Roving Frames
REFERENCE: Your memorandum, same subject, dated July 30, 1980.
In response to subject memorandum, the requirement of 29 CFR 1910.212(a)(1)
clearly states that guarding shall be provided to protect the operator and
other employees from rotating parts. Furthermore, 29 CFR 1910.212(a)(3)(ii)
requires point of operation guarding in conformance with any appropriate
standards. 29 CFR 1910.262(b)(27) defines the point of operation to mean
that part of the machine where the work of drawing or manipulating the stock
in any way is done. Since the roving frame does manipulate the stock, it is
a point of operation.
ANSI L1.1-1972, Safety Requirements for the Textile Industry, addresses the
situation and is an appropriate standard. Paragraph 13.2 of ANSI L1-1972,
states that the intent of the requirements is to provide protection from
hazards of point of operation, and feeding devices, among others.
The vertical standard 29 CFR 1910.262, Textiles, does not address
requirements for point of operation guarding. Therefore, the requirements of
29 CFR 1910.212 are applicable to textile machinery. Where employee
exposure to roving frames is substantiated, a violation of 29 CFR
1910.212(a)(1) or .212(a)(3)(ii) shall be cited.