Act Like the Person

Earlier in this program you learned to act like the carton. Now act like a person, specifically the person who uses this system and the person who services it. At 2 AM those are usually the same person.

A safety item spotted during scoping costs the project nothing. The same item found later comes out of your margin or turns into a change order.

The Categories You Check on Every Project

• Underside belt and roller protection, wherever an operator has access below the unit.
• Pull-cord E-stops along any run an operator can reach.
• Safety caging around automated cells and robotic equipment.
• Bearing covers and rotating-shaft guards at every drive location.
• Pinch and nip points where a hand, a glove, or a sleeve can get caught.

Guard by Exposure, Not by a Number

• There's no universal height that exempts a conveyor from underside guarding. No 96-inch rule, no magic clearance that waives a belly pan. If you learned one, unlearn it now.
• ASME B20.1 sets the duty by exposure: spill guards, pan guards, or equivalent are required wherever falling material or components could endanger personnel below, regardless of mounting height.
• Two real numbers live nearby, and neither is an exemption. ASME B20.1's 6 ft 8 in figure is an overhead clearance minimum for crossing aisles. OSHA's 1910.219 7-foot threshold governs exposed power-transmission parts, and it's 84 inches, not 96.
• The staircase makes the point. A person on the stairs can reach a run that looked untouchable from the ground. The floor measurement lied. Exposure didn't.

Pull Cords: the Mandate and the Field Practice

• Mandated, per CEMA SBP-002 with ASME B20.1: a slack-cable switch that trips if the cord is cut, broken, or goes slack, and the cord running the full accessible length.
• Also mandated, and numeric: an E-stop actuator within 5 feet of any fixed work station, and E-stop access within 25 feet for unit handling in general-access areas, 50 feet for bulk handling.
• Not codified: the 30-to-48-inch mounting height and the 10-to-12-foot eyelet spacing. Those come from the switch manufacturer's installation instructions. Field practice, never a code mandate.

Robot Cells and the Interlock Question

• Retire the cobot-versus-industrial-robot split. Safety is a property of the application and its risk assessment, not the marketing name on the arm.
• A cell may skip full perimeter guarding only when a documented risk assessment shows a recognized collaborative-application technique, under ISO 10218-1:2025 and ISO 10218-2:2025. Non-collaborative applications in the US: ANSI/A3 R15.06-2025.
• Ask the integrator for the risk assessment document. They usually have one.
• Every safety gate needs a safety-rated interlock. A standard limit switch on a safety gate isn't a safety device and isn't equivalent.

LOTO and the Map of Who Governs What

• LOTO is a design decision on the layout. Every isolation point reachable from the floor, without a ladder, without a second person, and not tucked behind equipment.
• ASME B20.1-2024 is the primary US consensus conveyor safety standard.
• OSHA general industry has no dedicated conveyor standard. Enforcement runs through 1910.212, 1910.219, and the General Duty Clause citing B20.1. Construction is the exception: 1926.555(a)(8) incorporates ANSI B20.1-1957.
• NFPA 70 is supporting: the electrical wiring, motors, controls, and firestopping of penetrations.

Walk It as the Person

Riverside

RIVERSIDE PROJECT

"We had two near misses last year. Carts coming down from upstairs crossing paths with a forklift in the main aisle. Nothing happened but it was close."

Run the guarding audit: the pull cords over roughly 300 feet of accessible run, the forklift crossing, the underside exposure on the mezzanine decline with the stairway named as its own exposure point, the bearing guards as factory options, and LOTO for a maintenance team of one. Every category turned into a priced line. That's the Part VI guarding deliverable.