OSHA's Standard Interpretation Letters
If you have visited the Occupational Safety and Health Administration's (OSHA's) Web site at www.osha.gov, you know that it includes a number of resources to help small businesses comply with workplace safety and health regulations. These resources range from pocket-sized Quick Cards to comprehensive eTools that provide detailed information on specific industries or workplace safety and health issues.
One resource that you may have overlooked is OSHA's collection of standard interpretation letters, which are OSHA's official responses to written questions about compliance with the agency's requirements. (Note that OSHA requirements are set by statute, standards, and regulations. OSHA's interpretation letters explain these requirements and how they apply to particular circumstances, but they don't create additional employer obligations.)
There are several ways to search the OSHA Web site for standard interpretation letters, including by date, standard number, and key word. For example, if you want to review OSHA's standard interpretation letters on the training requirements under OSHA's hazard communication standard, you could type key words into the search field (e.g., hazard communication training). You could also search by the standard number if you know it. In this example, the relevant standard is 29 C.F.R. § 1910.1200(h). You'll see that OSHA has posted standard interpretation letters on a variety of issues that arise under 1910.1200(h), including retraining employees who have been previously trained by another employer, providing training in a comprehensible language, and whether merely providing employees with Material Safety Data Sheets satisfies the standard's training requirements (it doesn't, by the way).
Writing a letter isn't the only way to get information from OSHA. You can also contact OSHA by calling the toll-free number at 1-800-321-OSHA (6742), submitting an e-mail question through the electronic mail form on OSHA's Web site, or calling your local OSHA Area Office. If you contact OSHA via the 800 number or by e-mail, you will receive responses in the form of links to or copies of existing OSHA materials, including any relevant standard interpretation letters.
However, if OSHA has not issued a standard interpretation letter that addresses your question, the only way to get an official OSHA response is the old-fashioned way - by writing a letter and mailing it to OSHA at: U.S. Department of Labor, Occupational Safety and Health Administration, 200 Constitution Ave., NW, Washington DC 20210. OSHA posts selected responses that it thinks will be helpful to others on its Standard Interpretations Web page.
So the next time to visit OSHA's Web site, take a moment to review the collection of standard interpretation letters. They can be a valuable resource for small businesses and others seeking guidance on OSHA requirements. If you don't find the answer to your question, you can write your own letter to OSHA.
This article provided by the U.S. Department of Labor Alliance Program.