Recently, a subscriber asked the following question:
If we have rotating machinery that is contained in latched cabinets, is it an OSHA requirement that we require the use of a tool to access these cabinets?
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This was our response:
OSHA’s machine guarding requirements at 29 CFR 1910.212 are performance-based, meaning that employers may use any effective method of machine guarding as long as it provides the needed protection. The regulation states:
“One or more methods of machine guarding shall be provided to protect the operator and other employees in the machine area from hazards such as those created by point of operation, ingoing nip points, rotating parts, flying chips and sparks. Examples of guarding methods are barrier guards, two-hand tripping devices, electronic safety devices, etc.” (29 CFR 1910.212(a)(1))
If you are enclosing rotating parts in latched cabinets as a form of machine guarding, it is important that employees cannot easily defeat the machine guarding method you have chosen. A 2006 OSHA letter of interpretation (LOI) states that “barrier guards must be affixed such that they cannot be easily defeated.” Although this LOI specifically applies to an access door for a trash compactor, the same conclusion applies here: “The door would need to be secured such that it could not be easily circumvented (e.g., by use of means such as fasteners not readily removable by the operator, a lock, etc.), or, if access is desired using only a latch, an interlock or other guarding method must be used.”
Therefore, based on the description in your question, you would need to use a lock, a special tool, or some other means of preventing employee access to the rotating parts enclosed within the cabinets unless you also use another guarding method such as an interlock.