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.

May 15, 1995

Mr. E.C. Arms, Jr.
Regulatory Specialist
Westvaco Chemical Division
Box 70848
Charleston Heights, SC 29415-0848

Dear Mr. Arms:

This is in response to your letter of February 24, 1995, regarding the adequate guarding of a process pump.

Your letter inquired whether guarding is required for a standard process pump used in the chemical industry. You described the pump as having a small open area (usually 2" x 4") that allows access to the stuffing box, and explained that the stuffing box is used to keep tension on the pump packing which keeps process fluids from leading out around the rotating shaft which is 1 1/8 inches in diameter and generally runs at 1800 RPM.

Section 29 CFR 1910.212(a) requires that rotating parts, among other components, are to be provided with machine guarding. Since the pump shaft is a rotating part, the guarding of the shaft would be required.

Although the exposed area and the diameter of the rotating shaft are small and the risk of sustaining serious injury may be low, there is a potential for a loose shirt, an unbuttoned sleeve, etc., to get in contact with the exposed area of the rotating shaft, and for an injury to occur.

The guarding of the exposed area of this rotating shaft, for example, can be of a simple inversed U-cover that could be hinged to the fixed stuffing box. This would not hinder the easy accessibility to the pump components that may need servicing.

Thank you for your interest in occupational safety and health. If you need further assistance, please contact Alcmene Haloftis of my staff at 202-219-8031.


Raymond E. Donnelly, Director
Office of General Industry Compliance