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.

February 13, 1981

MEMORANDUM FOR:     DONALD E. MACKENZIE
                   REGIONAL ADMINISTRATOR

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.