Guard heights for petroleum pumping units

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

April 2, 1976
Mr. J. D. Manney,
Coordinator
American Petroleum Institute
[Recipient address omitted]
Dear Mr. Manney:
Assistant Secretary Morton Corn has asked me to respond to your letter of March 15, 1976, regarding Subpart O -- Machinery and Machine Guarding, Mechanical Power-Transmission Apparatus. In addition, this confirms a telephone conversation with a member of my staff.
Your correspondence indicates confusion exists regarding the height of guards for pumping units. The Occupational Safety and Health Administration (OSHA) standard that applies to the guarding of cranks and connecting rods is 29 CFR 1910.219(b)(2), which reads:

Cranks and connecting rods. Cranks and connecting rods, when exposed to contact, shall be guarded in accordance with paragraphs (m) and (n) of this section, or by a guardrail as described in paragraph (o)(5) of this section.

29 CFR 1910.219(b)(2) appears to be definitive enough. Where an employee is exposed to a moving crank and connecting rods, this hazard shall be guarded by a standard guard or guardrail as described in the appropriate standards.
Table 0-12--Table of Standard Materials and Dimensions in Part 1910 requires standard guards to be at least 7 feet in height from the floor or platform level. 29 CFR 1910.219(o)(5)(i) requires guardrails to be 42 inches.
According to the preceding OSHA requirements, there are three alternatives:

1. No employee exposure
2. A 7-foot minimum height standard guard.
3. A 42-inch-high guardrail.

Where panels in guardrails are fitted with expanded metal or wire mesh as noted in Table 0-12, the middle rails may be omitted.
Where a State is enforcing safety and health standards under an 18(b) plan with OSHA, its enforcement and standards are required to be at least as effective as OSHA standards. This, however, does not prohibit more stringent state standards.
Sincerely,
Barry J. White
Associate Assistant Secretary
for Regional Programs