OSHA Machine Guarding: How to Protect Workers and Avoid Penalties

September 10th, 2024 by Dakota Software Staff

Machines drive much of modern industry worldwide—and some are more hazardous than others. Whether the hazards arise from the machine’s primary function (e.g., cutting or bending) or from any of its moving parts (pulleys, gears, belts, pistons, etc.), it’s imperative to protect workers. Failure to properly guard against these hazards can result in crushed appendages, amputations, blindness, burns, or even fatalities. Machine guarding is a key line of defense against these serious outcomes—and along with other controls, it’s crucial to your Environment, Health, and Safety (EHS) program.

Here we’ll take a look at what machine guarding consists of, the regulatory standards that address it, and some of the benefits that it can bring to your safety efforts.

What Is Machine Guarding, and Why Is It Crucial to Safety?

Moving machine parts can create safety hazards in many ways depending on the apparatus. These hazards may include nip or pinch points; rotating, reciprocating, or transversing motion; and flying sparks or debris, just to name a few. “Machine guarding” refers to any element of design, process, or supplemental device(s) that safeguard the machine’s operator and any other people in the vicinity from these hazards.

Machine guarding might include:

• Physical barriers that enclose hazardous machine parts or otherwise prevent accidental contact by operators or other workers;

• Safeguarding devices such as gates, restraints, or sensory technology that will either stop the machine altogether or cause the operator’s hands to withdraw from a danger area if the device is triggered;

• Relocating mechanisms to simply put distance between employees and any of a machine’s hazardous parts or motions (obviously, this is not always feasible depending on the machine’s design); or

• Warning labels, signs, or another form of “awareness barrier” that does not provide physical protection but clearly warns operators/employees of nearby danger. These warnings alone are usually not sufficient to be considered machine guarding, but they can provide an extra level of protection when used with other methods.

Regardless of the specific machine, proper machine guarding should have the following qualities:

• First and foremost, it should prevent contact with the hazard.

• It should be secure (i.e., it cannot be easily removed, tampered with, or otherwise circumvented). Ideally, it should allow for basic maintenance of the machine without requiring removal of the safeguards.

• It should not introduce a new hazard (e.g., a guard that creates a pinch point or sharp edge), nor should it interfere with work processes, which may incentivize machine operators to work around or otherwise ignore the safeguards.

Machine guarding efforts are essential to organizational safety for reasons beyond the prevention of serious injuries—they are also often required by law.

Regulatory Requirements

The regulatory requirements for machine guarding are more complex than most safety leaders realize. There is also the mistaken belief that the manufacturers of guarding equipment have ensured all safety requirements are met. Because of these factors, it’s no surprise that machine guarding violations were one of the Occupational Safety and Health Administration’s (OSHA) top 10 violations of 2023. OSHA standards under the Code of Federal Regulations (CFR) address machine guarding and related hazards across four industries:

• General Industry (29 CFR 1910, Subparts O and R). This standard covers definitions and general requirements for all machines, as well as specific regulations for machinery and/or special industries, including (but not limited to) woodworking machinery, abrasive wheel machinery, mechanical power presses, forging machines, textiles, and bakery equipment.

• Maritime (29 CFR 1917 Subpart G and 1918 Subpart I). These maritime standard subparts outline requirements for machine guarding in terminal operations, as well as guarding related to maintenance and repair work in the vicinity of longshoring operations.

• Construction (29 CFR 1926, Subpart I). The construction industry standard includes items relating to the machine guarding of hand and power tools, with individual regulations covering general requirements, jacks, air receivers, mechanical power-transmission apparatus, and more.

• Agriculture (29 CFR 1928, Subpart D). This subpart covers safety for agricultural equipment, which includes the guarding of farm field equipment, farmstead equipment, and cotton gins.

There are also 29 OSHA-approved State Plans that operate their own statewide health and safety programs. These State Plans must be at least as strict as Federal OSHA requirements, but in some states there are additional and/or more stringent safety requirements. If your operations are governed by a particular State Plan, be sure to check if there are additional requirements for machine guarding.

Beyond all of these standards, remember that there is also the General Duty Clause, which requires employers to provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.” If a machine poses a known hazard on the job, it’s the employer’s obligation to eliminate or mitigate this hazard—and machine guarding may be one way to meet this obligation.

The Cost-Benefit Calculus of Machine Guarding

Depending on the type of machine and the scope of your operations, there is always the chance that implementing various forms of machine guarding will require up-front investment, some of it significant. But these costs pale in comparison to the cost of noncompliance and potential serious injury to workers. These costs could include:

• Fines from agency citations. If OSHA inspections turn up violations of machine guarding standards, the resulting fines can be steep. As of January 2024, serious or other-than-serious violations could carry a maximum penalty of $16,131 per violation; willful or repeated violations carry a maximum of $161,323 apiece.

• Workers’ compensation and injury costs. Injuries may incur workers’ compensation costs, lead to time away from work, and result in short- or long-term disability—harming not only the employer’s bottom line but possibly also the injured employee’s ability to earn a living.

• Reputational costs. A careless attitude toward safety and an overall lackluster safety culture is likely to harm employee morale and productivity, hurt your organization’s recruitment and retainment efforts, and inspire a feeling of distrust not only among workers, but among the general public.

Staying on Guard, Staying Safe

Machines are vital to the success of many organizations—and machine guarding is just as vital to organizational safety, which serves to support and maintain that success. When paired with effective training, frequent inspections, and software solutions designed to proactively track and trend injuries, incidents, and near misses, machine guarding can help EHS leaders ensure the protection of their workforce.

View our demo library to see how Dakota Software can provide solutions that fit your unique safety and compliance needs.