WISHA Regional Directive 79-30

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WISHA Regional Directive 79-30

WRD 79.30

SUBJECT: WAC 296-24-15001(5) and WAC 296-24-205 - Equipment Guarding in Isolated Locations.

1. Purpose: To cancel WISHA Code Interpretation 74-8, dated October 30, 1974, and to provide uniform compliance action.

2. Background: Frequently equipment is located in areas so that its moving parts do not present the usual hazards to personnel. Typically such equipment might include fans on compressors or basements, etc. In reviewing Washington Industrial Safety and Health Act citations and notices, it is evident that some compliance personnel are citing certain conditions while others are not citing the exact condition in another location. The standards most commonly involved are WAC 296-24-15001(5), Machine Guarding Exposure of Blades and WAC 296-24-205, Mechanical Power-Transmissions.

3. Application: WAC 296-24-15001(5) states that when the periphery of blades of a fan is less than seven (7) feet above the floor or working level, the blades shall be guarded. OSHA, Region X, has issued an opinion that additional guarding on fans used to cool transformers is unnecessary if the transformer is isolated by lock and key. The Federal Register has proposed that the internal components of fans used for process cooling such as refrigeration condensers and cooling towers be excluded from the requirements of their fan-guarding section. The Washington Industrial Safety and Health Act interpretation of WAC 296-24-15001(5) would consider the fans guarded if the periphery of the blade is protected by a shroud, if only authorized service personnel are exposed and if the equipment is in a room or enclosure whose entry is controlled by lock and key at all times. WAC 296-24-20507(5) is explicit except for the reference to the illumination levels. The ANSI A11.1-1965 (R-1970) does not specifically list such rooms nor does our Chapter 296-62 WAC. By researching both sources and using levels specified for similar exposures we would interpret the proper level to be 10 foot-candles when such areas are occupied.

4. Action: The preceding Washington Industrial Safety and Health Act Interpretations shall be used in evaluating the employer's compliance with the intent of our code requirements.

5. Effective Date: This WISHA Regional Directive shall become effective on November 19, 1979.