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 29, 1996

Mr. Joe Kaczmar
Koolant Koolers, Inc.
2625 Emerald Drive
Kalamazoo, Michigan 49001-4542

Dear Mr. Kaczmar:

This is in response to your March 13 letter requesting interpretation of the machine guarding standard, 29 CFR 1910 Subpart O. Your question and our reply follow.

Scenario: Industrial processing equipment (condenser) fans are located within 7 feet (2.7 m) of a workplace floor.

Question: Would an employer have to comply with Table 0-10 under paragraph 1910.217 or does the guarding standard at paragraph 1910.212(a)(5) apply to the scenario above?

Reply: Fan guards are covered under paragraph 1910.212(a)(5). Table 0-10 under paragraph 1910.217(c) is applicable to mechanical power press point of operation guards.

We appreciate your interest in employee safety and health. If we can be of further assistance, please contact [the Office of General Industry Compliance Assistance at (202) 693-1850].


Raymond E. Donnelly, Director
Office of Safety Compliance Assistance