Do we have to install e-stops on older equipment?

OSHA’s machine guarding standards in 29 CFR 1910 Subpart O do not generally include exceptions for machines based on their age (there are a few date-related criteria in the mechanical power press standard in 1910.217 and also in the lockout/tagout standard in 1910.147). We are not aware of any letters of interpretation or OSHA guidance documents that indicate machines are exempt from machine guarding requirements because of their age. It would be up to the employer who is using the machine to ensure the machines are adequately guarded so that employees are not exposed to hazards.

However, whether or not the regulations specifically address emergency stops, depends on the type of equipment. OSHA only addresses emergency stop controls in a few standards. And, even in the standards where OSHA addresses emergency stops, they don’t provide a great deal of information. Absent a particular requirement, OSHA has used the General Duty Clause to cite for emergency stop issues. Beyond this information, we suggest contacting the manufacturer of the equipment and your local OSHA area office for guidance.