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.

January 8, 1992

Mr. Samuel J. Gualardo, CSP
Metropolitan Edison Company
Post Office Box 16001
Reading, Pennsylvania 19640

Dear Mr. Gualardo:

Thank you for your letter of November 13, 1991 requesting clarification on a previous interpretation of 1910.212(a)(5).

As we understand the situation, the issue is whether or not guards are required for fan blades on an electrical transformer as shown in the picture you provided.

As stated in your letter, the Occupational Safety and Health Administration's (OSHA) standard at 29 CFR 1910.212(a)(5) requires employers to protect employees from exposed fan blades. If working with or near equipment exposes an employee to a hazard, in this instance, fan blades, then guards must be provided. Part 29 CFR 1910.212(a)(5) provides that when the periphery of the blades of a fan is less than seven (7) feet above the floor or working level, the blades shall be guarded.

After studying the picture enclosed with your letter, we noted cages over the fans. OSHA standard 1910.212(a)(5) further requires that the guard shall have openings no larger than 1/2 inch. That requirement must be met.

There is no exemption from these requirements in the General Industry Standards.

If we can be of any further assistance, please do not hesitate to contact us.


Raymond E. Donnelly, Director
Office of General Industry Compliance Assistance