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.

August 3, 1989

The Honorable Robert H. Michel
Member, United States House of Representatives
100 N.E.
Monroe, Room 107
Peoria, Illinois 61602-1094

Dear Congressman Michel:

This is in response to your letter of June 22, addressed to Ms. Kathleen Harrington, Assistant Secretary, Office of Congressional Affairs, on behalf of the employees of Keystone Steel and Wire Company in Bartonville, Illinois. The employees expressed concern regarding the feasibility of OSHA's machine guarding requirements in their workplace.

The concerns raised are in relation to an inspection conducted at Keystone Steel and Wire in May of 1987. At the time of the inspection it was noted that the barb wire machines were not adequately guarded in that the tops of the machines were not enclosed. Citations which were issued alleging these hazards were contested and remain in litigation. The requirements of the standard are that guards shall be designed and constructed so as to prevent employees from having any part of their bodies in the danger zone during the operation cycle. We feel confident that an acceptable abatement will be derived by the company.

The Occupational Safety and Health Administration does not have a requirement that the guard be opaque or restrict the view of the operation in any way. Many guards are manufactured of expanded metal or of clear plexiglas and permit a clear view of the hazardous area while protecting the employees from harm.

Thank you for your interest in occupational safety and health. If we may be of further assistance, please contact us.


Alan C. McMillan
Acting Assistant Secretary