Machine Guarding and Hazardous Energy Control
Machine guarding basics
1910.212 requires one or more methods of machine guarding to protect the operator and other employees from hazards such as points of operation, ingoing nip points, rotating parts, flying chips, and sparks. The point of operation must be guarded on machines that expose an employee to injury. Guards must be attached to the machine, must not create new hazards, and must not be easily bypassed. Related sections: 1910.213 woodworking, 1910.215 abrasive wheels, 1910.217 mechanical power presses, and 1910.219 mechanical power transmission apparatus. Fixed machinery must be anchored. Fan blades less than 7 feet above the floor must be guarded.
Hazardous energy control (1910.147)
Lockout/tagout applies to servicing and maintenance where unexpected energization, startup, or release of stored energy could injure. It does not apply to cord-and-plug equipment where the plug is under the exclusive control of the employee doing the work, or to normal production operations - but it does apply the moment a guard is removed or bypassed to clear a jam or adjust the machine.
Required elements: a written energy control procedure for each machine; lockout devices (tags alone are not locks); verification by the authorized employee; release from lockout; annual periodic inspection; training for authorized, affected, and "other" employees; group lockout procedures; and notification of affected employees before and after lockout.
Traps
Candidates confuse the guarding standard with LOTO. Ask: is the employee operating the machine (guarding) or servicing it (LOTO)? Also, periodic inspection is at least annually, and it must be performed by an authorized employee other than the one using the procedure.
Worked example
A conveyor jams. Clearing the jam requires reaching past a removed guard - this is servicing, so the authorized employee must stop the conveyor, isolate and lock the disconnect, dissipate stored energy (gravity, springs, hydraulics), verify zero energy, then clear the jam.