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.

March 22, 1984

Mr. Don Brothers
Manager, Electrical Products
Harris Graphics Corporation
Bindery Systems Division
Champlain, New York 12919

Dear Mr. Brothers:

This is in response to your letter of February 16, regarding the extent to which Safety mats provide for compliance with Occupational Safety and Health Administration (OSHA) regulations for machine guarding.

Comprehensive machine guarding is provided through a system of components and integrated with effective employee training and supervision. OSHA's regulations predominately address the requirements for physical guarding. However, it is recognized that even the most comprehensive guarding concepts provide incomplete employee protection unless adequate training and supervision exist.

The OSHA regulations pertaining to machine guarding are delineated by 29 CFR 1910, Subpart O. Specifically, 1910.212 and 1910.219, copies enclosed, relate to the machines discussed in your letter. As you will note, the requirements of 1910.212 are performance oriented and require that employee exposures to hazardous portions of machines be prevented through the application of machine guarding. It further stipulates that "one or more methods ...shall be provided."

As you are aware, redundant guarding is desirable and on occasion necessary to achieve reliable safeguarding of employees from hazardous machine components. The application of safety mats has generally been to provide such redundant guarding. Employees are therefore guarded by location in addition to physical safeguards affixed to the machines.

Reliance upon safety mats alone for the prevention of injuries is an issue which must be evaluated on a case-by-case basis. Each such installation would require an analysis of the alternatives and an assurance that the system cannot be bypassed. In most instances, safety mats alone do not provide a degree of employee protection deemed necessary to meet the intent of OSHA's regulations.

If we may be of further assistance, please contact us.

Sincerely,



John B. Miles, Jr., Director
Directorate of Field Operations