Sept. 26: Red 'Letter' Day for OSHA

We're already seeing a spurt of new standards as the Bush administration nears its end, notwithstanding an OMB directive that suggested non-essential standards should not be issued at this point. Something similar happened last Friday when OSHA posted 14 letters of interpretation – a bounty that is hard to understand. These letters, useful to employers because they state how the agency’s enforcement officers will interpret a given situation against a certain standard, usually trickle out at a snail's pace.

The Sept. 26 haul touched several standards, including Hazard Communication, emergency eyewash and showers, safe sharps (bloodborne pathogens, BBP), the OSHA 10-hour construction safety training, HAZWOPER, and the powered industrial trucks standard. The letters themselves, signed by Richard Fairfax, director of OSHA's Directorate of Enforcement Programs, are dated in April and May 2008. It's typical for the agency to post letters months after the actual issuance and after they were received.

One of these new ones has Fairfax informing Dr. William A. Hyman of Texas A&M University's Department of Environmental Engineering that an employer's contractual relationship with a supplier, possibly steering the employer toward a certain safety device, does not override the BBP standard's key requirement (29 CFR 1910.1030) that the employer must minimize or eliminate employees' exposure, however that is achieved. Another, dated April 18, 2008, and answering a question from Moraima Lugo-Millan of Hazardous Materials Information Division of Defense Supply Center-Richmond, states that an MSDS stating that its information is "valid on the date of printing only" violates the HazCom standard (29 CFR 1910.1200) because it does not state the date of the MSDS's preparation. MSDSs are valid until the next time that that chemical is shipped to the user, Fairfax noted.

To read all of the letters, visit this OSHA site.

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