January 9, 2006

Mr. John Tignor
Safety & Ergonomics Director
Cargill, Inc.
East Highway 154
Dodge City, KS 67801

Dear Mr. Tignor:

Thank you for your February 9, 2005, letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You are requesting an interpretation of the OSHA standard 29 CFR 1910.219, and whether or not rotating round shafts must be guarded. Your paraphrased scenario, question, and our response are provided below.

Scenario: The exposed round shafts are completely smooth and have no bolts, holes, or keyways. The shaft's diameters that can be used are 3-inch, 4-inch and 4 5/16-inches. The length of the exposed shaft is approximately 7 inches. The shafts revolutions range from 17 to 54 per minute (rpm). The measurement from the outside of the motor mounts to the outside of the shaft varies from 8 inches to 13 inches depending on the equipment.

Question: Would OSHA provide an interpretation of 29 CFR 1910.219 as to whether these shafts must be guarded, because the manufacturer believes that the American National Standards Institute's (ANSI's) guarding requirements refer to rectangular shafts only?

Response: From your incoming letter, we were not able to determine the installation heights of the shafts. As you may know, §1910.219, Mechanical Power-Transmission Apparatus, does not reference square or rectangular shafts, nor does it exempt round shafts from its guarding requirements. Also, OSHA's standard provides no exemption for shaft size or speed (rpm).

OSHA standard, §1910.219(c)(2)(i) states, "All exposed parts of horizontal shafting seven (7) feet or less from floor or working platform, excepting runways used exclusively for oiling, or running adjustments, shall be protected by a stationary casing enclosing shafting completely or by a trough enclosing sides and top or sides and bottom of shafting as location requires."

However, 29 CFR 1910.219(c)(5), provides guarding exemptions for all mechanical power transmission apparatus located in basements, towers, and rooms used exclusively for power transmission equipment.

In addition, if the housing/mount is designed or constructed in such a manner as to prevent employees from having any part of their body, clothing, jewelry, or the like (such as neckties, scarves, and necklaces) contact the shaft, then it would be considered as guarded by location and would be compliant with the provisions of §1910.219(c)(2)(i). Otherwise, all rotating shafts seven feet or less from a floor or work platform must be completely enclosed as required by the standard.

Please note that ANSI's standards are promulgated for voluntary use, whereas OSHA's standards have enforceable mandatory provisions. Further, OSHA does not interpret consensus standards. For an official interpretation of American Society of Mechanical Engineers' standard, you may contact ANSI/ASME at:

The American Society of Mechanical Engineers
Secretary of the B15 Committee
Three Park Avenue
New York, NY 10016-5990
Phone: (212) 642-4900

Thank you for your interest in occupational safety and health. 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. If you have any further questions, please contact the Office of General Industry Enforcement at 202-693-1850.

Sincerely,



Richard E. Fairfax, Director
Directorate of Enforcement Programs