Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

October 6, 1975



SUBJECT: Clarification of Standard 1910.142


This is in response to your memorandum dated June 30, 1975, requesting an official interpretation of the word "temporary," and the possibility the above mentioned standard could be used in covering paid camp counselors.

This office is in full agreement with Mr. Gilbert's pervious interpretation of the word "temporary" as stated in your letter of April 22, 1974, quote: "referred to the state of employment and not to the physical structure housing the employees."

As discussed recently with Mr. Garvey of your office, the National Office staff members of the Standard Development group have stated that it was not the intent of the ANSI Standard Committee for Z4.4-1968, source standard for 29 CFR 1910.142 temporary labor camps, to include recreational type camps under this standard. The general inference of this standard directs itself to employees engaged in farming, logging, and/or fruit or vegetable pickers. Therefore, the type camp mentioned in your correspondence would not fall under the 1910.142 standard. Of course in the case of a compliant, OSHA would have to investigate and cite alleged violations as in any normal complaint. It has not been OSHA's policy to inspect these camps, especially the non-profit organizations.

Barry J. White
Associate Assistant Secretary
for Regional Programs