Tuesday, May 1, 2012

Finding OSHA Letters of Interpretation is a Snap (or a few clicks, actually)

Have you ever had a question about a particular OSHA standard? If so, the odds are good that your question has already been asked and answered by OSHA in what is known as a “letter of interpretation”. The Occupational Safety and Health Administration (OSHA) has issued thousands of letters of interpretation over the years to answer questions posed by people about various health and safety standards. These letters are available on the OSHA website, and provide a valuable resource when you are researching a particular standard. But many people have difficulty finding the letter(s) that apply to the particular OSHA regulation(s) they are researching. So I wanted to make you aware of how easy it is to locate the OSHA letters you are seeking.

When you visit the OSHA website, they have a page for interpretation letters that lists each Part (e.g.: Part 1910, Part 1917 . ..) of the OSHA regulations. You can search for letters applicable to a particular OSHA standard by clicking on the Part in which the standard appears, then drilling down through each section and the corresponding list of letter titles until you find the letter(s) for the standard you need.

But for me, the easiest method to find out if there are any letters of interpretation (or OSHA directives) associated with a particular standard is to just go directly to the OSHA standard you are researching on the OSHA website and see if the standard heading is hyperlinked. For example, here is the link to the OSHA General Industry standards for Emergency Action Plans. Click on that link and you will see each paragraph of that section listed. Pay close attention to each paragraph heading (e.g.: 1910.38(a), 1910.38(b), 1910.38(c) . . .); some of them are blue and underlined, and some are gray and not underlined.

The ones that are blue and underlined are hyperlinked to a list of the letter(s) of interpretation (and OSHA directives too, where applicable) associated with that particular paragraph.  And the ones in gray do not have any letter of interpretation associated with the standard. For example, 1910.38(b) is the OSHA standard that details when it is and is not necessary to have your emergency action plan in writing. Once you access the page for that standard, click on the the hyperlinked heading for 1910.38(b), and you will be directed to a link to a  letter of interpretation that expands on that particular regulation.

Of course, you must keep in mind that OSHA letters of interpretation are very specific to the circumstances addressed in each particular letter, so do not over-reach and try to apply their guidance to a scenario that is different than the one posed in the letter. And it is possible there may be no letter associated with the particular standard you are researching, or, there may be several. Also keep in mind that OSHA letters of interpretation can become obsolete when the associated standard is revised. And be aware that OSHA will has been known to revise an old letter of interpretation on occasion, so check the ones that are of most importance to you every once in a while to make sure you have the latest information.

OSHA letters of interpretation can be very useful when researching an OSHA regulation, and finding them can be a snap (or a few clicks, actually) when you use the methods described above. Please let me know if you have any comments or questions regarding OSHA letters of interpretation by clicking the link to the "comments" section below, and please share a link to this blog post with others in your network that can benefit from this information.

7 comments:

  1. Thanks, good link! Ron.

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  2. Good info Curtis. Thanks.

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  3. Good information Curtis. I guess being a retired OSHA Representative and going onto the www.osha.gov web site everyday for the past 30 plus years, one takes navigating the site for granted......I used that information (navigation ability) as somewhat of a "magic trick" now as a "Private EH&S Consultant". I would impress my clients with the knowledge I have in my capability to explain the application and interpretations of regulatory standards, quoting "directives", "interpretations", "recent rulings", required activity noted in the CSHOs FOM. It was great and they loved it. Now, you come along and tell everybody how I did it. Thanks, thanks allot. LOL! Really though, good information and I hope everybody uses it. Have a safe day.

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  4. Great info Curtis. I'll give you some feed back as I use it.

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  5. Thanks alot for the information!So much better than using the search box and sifting through the unrelated search results.

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  6. Thanks for the information. How do the ARCHIVED interpretations play a role in OSHA hearings, can they be referenced as an interpretation?

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    1. OSHA interpretations do change from time to time, so they will often archive old letters that may no longer be applicable. Basically, an OSHA Archive Document may no longer represent OSHA policy, and is presented in the archives as historical content, for research and review purposes only.

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