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 http://www.osha.gov.

 

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 http://www.osha.gov.

 


December 15, 1980

 

 

 

MEMORANDUM FOR: REGIONAL ADMINISTRATORS
 
THROUGH: JOHN MILES FIELD COORDINATOR
 
FROM: BRUCE HILLENBRAND, ACTING DIRECTOR
FEDERAL COMPLIANCE AND STATE PROGRAMS
 
SUBJECT: Oil Rig Inspection

 


This memorandum supersedes the January 1979 memorandum on this subject to Gilbert Saulter, Regional Administrator, Region VI. The above memorandum begins with the following sentence:

 

 

Kelly bushings on oil drilling rigs that are smooth and do not present a potential hazard to employees that might come in contact with the bushings, do not require guarding.

Disparities in the interpretation of this sentence and the subsequent compliance with 29 CFR 1910.212, general requirements for all machines, have been noticed.

Generally speaking, operational kelly bushings and rotary tables are hazardous and should be cited, unless properly guarded.

Examples of hazards presented by kelly bushings are objects coming in contact with protuberances and being propelled outward toward employees; chains or hoses being entangled in the presence or absence of irregularities on the surface thereof; etc.

Rotary tables are also included in this memorandum because of their proximity to kelly bushings, the similarity of hazards and the application of standards. Since most of the hazards associated with kelly bushings and rotary tables relate to those created by points of operation, ingoing nip points, rotating parts, slings, falls, etc., the appropriate standards to be cited are 29 CFR 1910.212(a)(1), 1910.212(a)(2), and/or 1910.212(a)(3)(ii).

It has further been determined that some companies in the drilling industry have been successfully using guarding for the kelly bushings and rotary tables. Manufacturers of these guards are:

KBG Manufacturing Co. Inc.
1811 Donna Drive
Franklin, Louisiana 70538
Varco International Inc.

Co. 800 North Eckhoff St.
P.O. Box 6626
Orange, California 92668

 

 

[Corrected 3/20/2009]