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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.
This memorandum is in response to a request for interpretative guidance as to whether all unguarded machinery and power transmission apparatus in food processing facilities are required to be guarded. The guidance is that all unguarded machinery and power transmission apparatus must be guarded.
The applicable regulations (1910.212 & 1910.219) do not exempt such facilities from compliance nor do they allow a lesser degree of protection for their employees. Additionally, the issue some food processing employers raise regarding the difficulties of designing guards that do not cause contamination of the product does not relieve or reduce their responsibilities.
The Food and Drug Administration does not have any rules or regulations that prohibit the guarding of machinery or power transmission apparatus. Their position on this issue is that any guards must not cause any contamination of the food products.
If you need any additional information regarding the preceding, please contact John McFee at FTS 596-1201.