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.

March 21, 1990

The Honorable Joseph E. Brennan
Member, United States
  House of Representatives
177 Commercial Street
Portland, Maine 04101

Dear Congressman Brennan:

Thank you for your letter of December 21, 1989, addressed to Ms. Ruth Knight, Director, Office of Intra-Governmental Affairs, concerning a recent inquiry made by your constituent, Mr. Maurice Libner, regarding Occupational Safety and Health Administration (OSHA) regulations that pertain to drilling rigs. Please accept my apology for the delay in this response.

One of the enclosures with your letter was a letter dated May 14, 1982, from Mr. Robert E. Dickinson, the President of Mobile Drilling Company, Inc., to the U.S. Department of the Interior. You expressed concerns with respect to Mr. Libner's statement that "OSHA and other agencies are unclear . . . in their regulations pertaining to safety on drilling rigs."

To safeguard employees from rotary actions involved in drilling operations, where machine guarding is required, employers are obligated to comply with OSHA's general industry standards contained in Subpart O of 29 CFR 1910, Machinery and Machine Guarding. A copy of the relevant standard is enclosed. The OSHA standard at 29 CFR 1910.212(a)(1) establishes general requirements for machine guarding and is applicable to all types of machinery which are not covered by specific OSHA standards. The language of the standard is performance oriented, meaning that employers may choose the most suitable method for protecting their employees.

Due to the wide variety of drilling equipment available it would be quite difficult to develop specific safety standards for every responsibility to provide suitable guards to protect employees from hazards. In his letter, Mr. Dickinson remarked that "some [employers] provide appropriate protection are not complying with the Occupational Safety and Health Act and OSHA regulations.

In addition to requiring appropriate machine guarding, OSHA also requires employers to train employees to recognize and avoid hazards.

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


Gerard F. Scannell
Assistant Secretary