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29 CFR 1910.212(a)(5) February 10, 1975

Mr. Hugo W. Plaag
Director of Risk Management
Giant Food, Inc.
Box 1804
Washington, D.C. 20013

Dear Mr. Plaag:

Assistant Secretary John H. Stender has asked me to respond to your letter dated January 21, 1975, relative to Section 1910.212(a)(5) Machine Guarding, Exposure of Blades, of the Occupational Safety and Health Standards.

The additional information supplied to you has been evaluated and has been discussed with Mr. Pugh of your staff. The guarding requirements of the above standard, as they relate to the moving parts of your fans, are valid. As an alternative to these guarding requirements, you have suggested modifying the fans to restrict their usage to "low speed". This is not an acceptable alternative.

We understand that there are only a relative few fans that are located in areas that due to the close proximity to other parts of the structures cannot be raised to the required seven feet. Since they are used primarily for decorative purposes we suggest that they be completely disconnected electrically. In those instances where the movement of air is needed, suitable floor or wall fans should be utilized.

No further action is contemplated in your request for variance from Section 1910.212(a)(5) dated November 24, 1974.


Barry J. White
Associate Assistant Secretary for
Regional Programs