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.

April 15, 1993

Ms. Ellen Babcock, Regulatory Safety
and Environmental Specialist
Becton Dickinson
Primary Care Diagnostics
7 Loveton Circle
Sparks, Maryland 21152-0370

Dear Ms. Babcock:

This is in response to your letter of January 4, and to your telephone conversations of February 4 and March 5, with Mr. James C. Dillard, a member of my staff, in which you requested an interpretation of whether the Occupational Safety and Health Administration's (OSHA) 29 CFR 1910.212 standards apply to tabletop centrifuges that are designed for use in physicians' offices and laboratories.

During the telephone conversations, Mr. Dillard informed you that the specific standard at 1910.212(a)(4) does not apply to tabletop centrifuges, and that there are no OSHA standards written specifically for tabletop centrifuges. This letter is written to confirm the information provided by Mr. Dillard. Although such machines are not specifically mentioned in the machine-guarding regulations and are not covered by the particular provision at 1910.212(a)(4), the general provision at 1910.212(a)(1) does cover hazards created by rotating parts or the point of operation. Accordingly, centrifuges that present such hazards must comply with the provisions of .212(a)(1), (a)(2), and (a)(3). An interlock would seem to be the most effective type of guard for this situation, although under the general provision other types of guarding may be used provided they meet the requirement of being "designed and constructed [so] as to prevent the operator from having any part of his body in the danger zone during the operating cycle".

If we can be of further assistance, please feel free to contact Mr. Dillard.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs