Question 9. What are OSHA’s Standard Interpretation Letters?
OSHA frequently publishes interpretations and guidance documents related to its standards. These interpretations and guidance documents are known as advisory documents. The purpose of these advisory documents is to advise employers and employees on a variety of issues related to health and safety in the workplace.
One resource businesses have to determine compliance with interpretation of OSHA regulations is OSHA’s collection of standard interpretation letters, which are official responses to written questions about compliance with the agency’s requirements.
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. You could also search by the standard number if you know it.
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.
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. OSHA posts selected responses that it thinks will be helpful to others on its standard interpretations web page.
The next time you visit OSHA’s Web site, take a moment to review the collection of standard interpretation letters. They can be a valuable resource for businesses seeking guidance on OSHA requirements. If you don’t find the answer to your question, you can write your own letter to OSHA.
It's important to 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. Advisory documents do not have the force and effect of the law. Therefore, OSHA cannot issue citations to employers based on violations of advisory documents.
(Question #9 – February 2017 – Delta Companies Group)
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