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.

May 8, 2012

Mr.Miles Free

Director, Industry Research and Technology
Precision Machined Products Association
6700 West Snowville Road
Brecksville, Ohio 44141-3212

Dear Mr.Free:

Thank you for your letter of February 7, 2012, to the Occupational Safety and Health Administration (OSHA), where you summarize issues brought to the attention of Assistant Secretary David Michaels during a recent meeting. You indicated that 29 CFR 1910.212(b)[1] has been interpreted inconsistently in its enforcement, as it applies to fixed machinery. As an example, you indicated that you have benches and pedestals that you do not bolt to the floor because these bench/pedestals are moved around.

OSHA standard 29 CFR 1910.212(b) requires machines designed for a fixed location to be securely anchored to prevent walking or moving. However, work benches or pedestals do not have to be secured when there is no fixed machinery mounted to the work surface that would create a movement hazard to the employees. Machinery, such as grinders or buffers, must be secured to a work bench or pedestal and the bench or pedestal, in turn, must be secured to the floor to prevent walking or moving. In instances where employers rely upon other effective devices to prevent machine movement, OSHA would most likely not issue a citation for a violation of this standard.

We appreciate your concerns and hope you find our response to be helpful. If we can be of further assistance to you, please contact the Office of General Industry and Agricultural Enforcement at (202) 693-1850.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs


[1] 1910.212(b): Anchoring fixed machinery.Machines designed for a fixed location shall be securely anchored to prevent walking or moving.