OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

December 8, 1975

Mr. L. C. Nicholas, P.E.
H. K. Ferguson Company
One Erieview Plaza
Cleveland, Ohio 44114

Dear Mr. Ferguson:

This is in response to your letter dated July 30, 1975 and October 9, 1975, which requested clarification of [29 CFR 1910.36(g)(1)] and 1910.212.

Confirming Mr. Jeff Campbell's telephone call on November 10, 1975 the 6'-8" head room requirement for emergency doors is required regardless of the location of door closure hardware.

Your second question concerned 1910.212, machine guards or vertical mounted units. As stated in 1910.212 one or more methods or machine guarding shall be provided to protect the operator and other employees in the machine area from hazards. 29 CFR 1910.219 provides specific requirement for guarding of mechanical power transmission apparatus.

If I can be of any further assistance, please feel free to contact me.


John K. Barto, Chief
Division of Occupational Safety Programming

[Corrected 05/28/2004]