The Cal/OSHA Standards Board has adopted a revised “note” for a safety order on conveyor guarding. It may have made a controversial requirement even more controversial. 8 CCR §3999 for conveyors states Belt conveyor head pulleys, … shall be guarded. The guard shall be such that a person cannot reach behind it and become caught in the nip point between the belt, chain, drum, pulley or sprocket. There is a note for the standard which states Normally, conveyor belt support rollers need not be guarded unless they create a potential hazard for serious injury. The Standards Board wanted a change to the note as it did not provide employers clear and precise direction. Personally, I have also found this requirement vague and difficult to advise employers about compliance. What was meant by “normally” and using a threshold of “serious injury” seemed less protective for workers.
In an attempt to clarify the standard, the Standards Board amended the note to read: “Conveyor belt support rollers need not be guarded unless they create a potential hazard as described in Section 4002” Section 4002 requires guarding for machines that create hazards from revolving, reciprocating…rolling…, including pinch points and shear points, not guarded by the frame of the machine(s) or by location by shall be guarded. Changing the note from “serious injury” to “potential hazard” doesn’t appear to be much better. I believe the Standards Board amendment went from being not protective enough to overly broad. Does the change provide employers clear direction? It appears doubtful. We will see how Cal/OSHA compliance inspectors apply the standard. I suggest you review any operations where powered rollers are used. If the roller creates a pinch point where injury could occur explore means to guard it. Contact The Cohen Group if you have any questions on whether guarding is recommended.