Don’t Rage Against the Machine Guarding: How to Comply with One of OSHA’s Most-Cited Regulations at 29 CFR 1910.212

OSHA frequently cites employers for failing to comply with the machine guarding requirements described by 29 CFR 1910.212.  In fact, this regulation landed on OSHA’s Top 10 Most Frequently Cited Standards for Fiscal Year 2025, a list that remains relatively consistent year-over-year.  Machine guarding requirements are not a flash in the pan that will land on the dust pile of agency enforcement.  Rather, the obligations described by 1910.212 should be top of mind for employees each day.

How can employers comply with OSHA’s general machine guarding regulation at 29 CFR 1910.212?

OSHA’s general machine guarding requirements at 1910.212 are far-reaching, but as a performance standard, grant employers flexibility on how to implement controls to achieve the goal of protecting employees.  To fulfill their obligations under the regulation, employers must first and foremost review and understand its demands.

• 1910.212(a)(1) mandates the use of “one of more methods of machine guarding” to protect employees “from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks.”  It provides multiple examples of possible guarding methods, including “barrier guards, two-hand tripping devices,” and “electronic safety devices.”

• 1910.212(a)(2) requires employers to attach guards to equipment, or elsewhere if direct connection is not possible, in a way that precludes the guard from presenting its own hazard(s).

• 1910.212(a)(3)(i)-(iii) explains machines’ points of operation, i.e., “where work is actually performed,” must be guarded when use of the equipment exposes employees to injury.  Guarding must keep all parts of an employee’s body outside the danger zone during operation, and tools for material handling must be used to supplement, but not replace, the protections provided by guarding.  OSHA provides examples of machines that typically require guarding at their points of operation in 1910.212(a)(3)(iv).

• 1910.212(a)(4) directs employers to use guarding enclosures around “[r]evolving drums, barrels, and containers” and to interlock those enclosures with the containers’ drive mechanisms to prevent rotation unless the enclosures are properly placed.

• 1910.212(a)(4) addresses fan blades, indicating they must be guarded when less than seven feet above a work area, with guard openings no greater than a half inch.

Finally, 1910.212(b) demands secure anchoring of fixed-location machines to prevent their movement.

What enforcement activity might employers face?

As noted previously, 1910.212 is one of OSHA’s most cited regulations, so enforcement activity concerning machine guarding already operates at a high clip.

In addition, OSHA’s ongoing National Emphasis Program (“NEP”) on Amputations in Manufacturing Industries, CPL 03-00-027, explicitly identifies 1910.212 as amputation hazard related (along with 29 CFR 1910.147, 1910.213, 1910.217, and 1910.219).  The NEP allows OSHA to inspect establishments and work practices regarding machine guarding.  It also authorizes OSHA to expand an inspection beyond the NEP’s scope if evidence indicates there may be additional violations at the location.  That is, an NEP inspection could lead to OSHA opening more cans of worms if OSHA 300s, employee interviews, or “plain view” observations indicate additional issues.  OSHA can go the other direction as well – expanding ongoing inspections into NEP inspections if the employer’s NAICS code is listed on NEP Appendix B.

Employers subject to NEP inspections can expect CSHOs to evaluate exposure to nip points, pinch points, shear points, cutting hazards, and other operation points and to evaluate potential teammate exposures to amputation hazards during setup, regular operation, clearing jams, adjustments during machine operations, cleaning, oiling or greasing, scheduled/unscheduled maintenance and/or servicing, and activities related to the control of hazardous energy.

Should OSHA find violations during an NEP or other inspection, employers are subject to monetary penalties that vary depending on the type and classification of the issued citations. [SH2] 

Type of Violation	Penalty
Serious Other-Than-Serious Posting Requirements	$16,550 per violation
Failure to Abate	$16,550 per day beyond the abatement date
Willful or Repeated	$165,514 per violation

How should employers improve machine guarding safety and reduce risk?

To provide a safer workplace and limit the potential for OSHA violations, employers should:

• Assess guarding risks and deploy compliant controls, such as appropriate guards, anchors, and interlocks.
• Conduct self-audits, documenting compliance and correcting any identified concerns.
• Review, revise, communicate, and enforce clear policies and procedures for machine guarding.
• Train employees to recognize and respond to machine guarding hazards, including reporting concerns to proper personnel.
• Implement robust Lockout/Tagout (LOTO) programs and equipment-specific procedures to dovetail with machine guarding to bolster risk reduction.  OSHA frequently pairs citations under these separate but related standards, so employers should remain attentive to their obligations under both.

Conn Maciel’s nationwide OSHA & Workplace Safety group stands ready to answer your OSHA machine guarding questions, so please feel free to contact us directly to discuss.