Scrap Metal Baler Guarding Under 29 CFR 1910.212: 2026 Audit Priorities

Frequently Asked Questions

Does OSHA require both guarding and lockout on scrap balers and shears?

Yes. Guarding under 29 CFR 1910.212 protects employees during normal operation, while lockout under 29 CFR 1910.147 applies during servicing, maintenance, and jam clearing.

Is shutting off power enough before clearing a jam in a hydraulic baler?

No. The article explains that stored hydraulic energy can remain after shutdown, so the procedure must include bleed-off, blocking, or another method to control trapped pressure before entry or reach-in work.

What machines should a scrap yard audit first?

Start with the highest-exposure equipment: auto shredders, hydraulic alligator shears, and two-ram balers, especially where workers clear jams, tie bales, inspect chambers, or work near elevated components.

What makes a machine safety audit more defensible?

A defensible audit is task-based and machine-specific. It breaks each job into steps, identifies hazards, ranks risk, and ties each exposure to a practical engineering or administrative control.

What are common red flags during a baler or shear audit?

Major red flags include missing guards, defeated interlocks, no machine-specific lockout procedure, vague depressurization steps, and employees reaching into hazard zones during troubleshooting or jam clearing.