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Point-of-operation guarding on a wire terminal machine

Summary A company asked whether a specific automated wire terminal machine needed point-of-operation guarding. OSHA said the submitted design appeared to make access difficult and included interlocks and a lockable disconnect, so extra guarding did not appear necessary for that setup. It warned this was not a blanket waiver and that inspectors must assess each installation; OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-01-08-0
Date issued
January 8, 1991
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Machine Guarding
Source
View the official document

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OSHA archives this letter and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

JAN 8 1991

Mr. Ronald D. Schaible, CIH
Manager,
Corporate Safety
and Industrial Hygiene Department
[Recipient address omitted]

Dear Mr. Schaible:

This is in response to your letter of November 2, regarding the AMPOMATOR CLS II Wire Terminal Machine, and whether in our opinion, point of operation guarding is required. We apologize for the delay in this response.

Members of our staff reviewed the submitted material, which clearly showed an automatic operation, with the point of operation located in a position that would be difficult for an employee to reach. The point of operation was small enough to prevent fingers from easily gaining access. In addition, the interlock switch on the main control box, as well as a main power disconnect, capable of being locked out, add to the safe operation of this machine. Considering all of the above we would concur that no point of operation guarding appears necessary. However, the opinion given here should in no way be construed as a blanket waiver on this machine from the point of operation requirements. Occupational Safety and Health compliance officers must evaluate each situation they encounter and apply the standard accordingly.

Your interest in safety and health is appreciated. If we may be of further assistance, please do not hesitate to contact us.

Sincerely,
Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance

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