May 8, 2023

Shin Agatsuma
Project Planning and Development Manager
TEXEL-SEIKOW U.S.A., Inc.
4404 W 12th St.
Houston, TX 77055

Dear Mr. Agatsuma:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding guards for both belt and shaft drives on your blower motors. 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. Your paraphrased scenario, questions, and our responses are provided below:

Scenario: Motors between one-half to 150 horsepower are used on blowers based on gas pressure and gas volume. A belt guard and shaft guard have been installed on the blowers to prevent accidental contact. Guards are made of fiberglass reinforced material (FRP).

Question 1: Does OSHA have any specific requirements regarding dimensions of gaps between the moving parts (belt or shaft) and the guards?

Response: Yes. OSHA's standards at 29 CFR § 1910.212 and 29 CFR § 1910.219 apply to the safeguarding of machines and mechanical power-transmission equipment and require guarding to protect the operator and other employees in the area from hazards such as those created by ingoing nip points, rotating parts, flying chips, and sparks.

In regard to gap dimension between belts and their respective guards, § 1910.219 (e)(1)(i) states, "Where both runs of horizontal belts are seven (7) feet or less from the floor level, the guard shall extend at least fifteen (15) inches above the belt or to a standard height except that where both runs of a horizontal belt are forty-two (42) inches or less from the floor, the belt shall be fully enclosed in accordance with subparagraphs (m) and (o)."

Please note that the requirements for guarding belts contained in 29 CFR § 1910.219 do not apply to the following types of belts when they are operating at two hundred and fifty (250) feet per minute or less:

1. Flat belts one (1) inch wide or less;
2. Flat belts (2) inches wide or less, which are free from metal lacing or fasteners;
3. Round belts one-half (1/2) inch or less in diameter; and
4. Single strand V-belts, thirteen thirty-seconds (13/32) inch wide or less.

An employer is responsible for determining whether 29 CFR § 1910.219 applies based on the specific working conditions present at their worksite.

Question 2: Does OSHA accept fiberglass reinforced plastic (FRP) as a material for guard construction for belts and shafts?

Response: OSHA will not issue citations to an employer that properly uses a non-metal guard so long as the guard is constructed of a substantial and suitable material. OSHA standard, 29 CFR § 1910.219(m)(1)(i) states, "Standard conditions shall be secured by the use of the following materials. Expanded metal, perforated or solid sheet metal, wire mesh on a frame of angle iron, or iron pipe securely fastened to floor or to frame of machine."

However, in an OSHA letter of interpretation to Mr. Stephen Wilson, which can be found at www.osha.gov/laws-regs/standardinterpretations/1999-02-08, OSHA stated the following:

OSHA has taken the position that guards constructed of any substantial material may be an acceptable alternative to the metal construction required by the standard at 29 CFR 1910.219(m). Until such time as the standard is modified, we are not in a position to deviate from that interpretation, and OSHA will continue to regard the use of suitable materials other than metal as a de minimis violation but will not be cited.

OSHA's de minimis enforcement policy is that if an employer complies with the clear intent of a standard but deviates from its particular requirements in a manner that has no direct or immediate relationship to employee safety or health, then the condition will be considered de minimis. Citations are not issued for de minimis conditions.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, such letters may be affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have any questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Kimberly Stille, Director
Directorate of Enforcement Programs