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Exit-door headroom and vertical machine guarding

Summary An engineering company asked about emergency-door headroom and machine guards on vertical units. OSHA said the 6-foot-8-inch clearance applied regardless of door-closure hardware position. It pointed to general machine-guarding and power-transmission-guarding provisions for the second issue.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-12-08
Date issued
December 8, 1975
Status
Active
Status last verified October 10, 2026

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December 8, 1975
Mr. L. C. Nicholas, P.E.
H. K. Ferguson Company
[Recipient address omitted]
Dear Mr. Ferguson:
This is in response to your letter dated July 30, 1975 and October 9, 1975, which requested clarification of [29 CFR 1910.36(g)(1)] and 1910.212.
Confirming Mr. Jeff Campbell's telephone call on November 10, 1975 the 6'-8" head room requirement for emergency doors is required regardless of the location of door closure hardware.
Your second question concerned 1910.212, machine guards or vertical mounted units. As stated in 1910.212 one or more methods or machine guarding shall be provided to protect the operator and other employees in the machine area from hazards. 29 CFR 1910.219 provides specific requirement for guarding of mechanical power transmission apparatus.
If I can be of any further assistance, please feel free to contact me.
Sincerely,
John K. Barto, Chief
Division of Occupational Safety Programming
[Corrected 05/28/2004]

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