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Flying-scale guards on forging hammers

Summary A forge sought a variance from the requirement for a scale guard behind its hammers. OSHA said the described operation fell outside that requirement because operators worked around the hammers and no other employees were exposed nearby. It said a barricade should be installed if operations changed so employees worked within six feet, and it treated the variance application as moot.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-02-14
Date issued
February 14, 1975
Status
Active
Status last verified October 10, 2026

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February 14, 1975

Mr. D. H. Scott
President
Delaware Alloy Forge Company
[Recipient address omitted]

Dear Mr. Scott:

This is in reference to your application for a variance from Section 1910.218(a)(3)(viii) Forging Machines - Hammers and Presses, of the Occupational Safety and Health Standards.

Section 1910.218(a)(3)(viii) requires that a scale guard be provided at the back of every hammer to stop flying scale. The requirement for the guard at the back of the hammer is to protect other employees from flying scale. The operators would be at the front of the hammer protected from the flying scale by proper protective clothing. In addition, it is recognized that a scale guard on the front of the hammer would interfere with the work procedures.

Your variance application and the information obtained in the visit to your facility indicate that your forging hammers do not fall within the scope of the standard in that the operators work completely around the hammer, and that there are no other employees working within 20 feet of the hammer. Therefore, there are no employees exposed to a hazard from the flying scale and a scale guard is not required.

If the current operations should change so that there are other employees within 6 feet of the forging hammers, a barricade should be installed behind the operators to prevent flying scale from striking these employees. Frequent cleaning of the area is also necessary to maintain good housekeeping.

Accordingly, no further action will be taken on your variance application. The interim order granted in the Federal Register of July 2, 1974 (39 FR 24442) is now moot.

Sincerely,
Barry J. White
Associate Assistant Secretary for
Regional Programs

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