|OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.|
June 5, 1990
||LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS|
||PATRICIA K. CLARK DIRECTOR DESIGNATE|
[DIRECTORATE OF ENFORCEMENT PROGRAMS]
||Enforcement Guidance - Use of NFPA 1124-1988 when inspecting Fireworks Manufacturing Facilities|
The present OSHA Instruction [CPL 02-00-073 (formerly CPL 2.73)] dated February 3, 1986, references the National Fire Protection Association (NFPA) standard, Code for the Manufacture, Transportation, and Storage of Fireworks, NFPA 1124, published in 1984. Since the NFPA standard has now, a newer edition published in 1988, we are advising the field to use the 1988 version of the NFPA standard as necessary, in the issuance of citations. OSHA Instruction [CPL 02-00-073] will be revised in the near future to reflect this change.
Please provide a copy of this memorandum to State Designees and [21(d) Consultation Project] Managers to ensure that they are aware of OSHA's enforcement policies in this regard.