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 https://www.osha.gov.

(Date Unreadable)

Mr. Donald A. Bell
General Manager
Alaska Loggers Association, Inc.
111 Stedman, Suite 200
Ketchikan, Alaska 99901

Dear Mr. Bell:

Assistant Secretary Auchter has asked me to respond to your letter of July 1, 1982, concerning the application of the hearing conservation standard to the logging industry. Please accept my apology for the delay in responding.

For rulemaking and compliance purposes, the Occupational Safety and Health Administration (OSHA) has established four industrial classifications: agriculture, construction, maritime and general industry. In this manner, OSHA enforcement efforts can better respond to the types of workplace hazards characteristic of each classification.

When classifying an industry, OSHA considers several factors, such as the nature of the industry's operations, the types of workplace hazards associated with the industry, and how other Federal agencies have classified the industry. Based on these factors, the logging industry has always been considered by OSHA to fall under the general industry classification. In light of your letter and similar letters from other loggers, we have reviewed our classification of the logging industry and have concluded that the current general industry classification is appropriate. Since OSHA's hearing conservation standard applies to general industry, the logging industry is subject to its provisions.

However, OSHA is currently considering revisions to the hearing conservation standard which provide some relief for the logging industry. For instance, we are considering extending the required time period in which to test new employees. Therefore, testing of short-term employees would not be required. Since the logging industry's workforce is highly transient, the time period extension could remova a large proportion of its workers from the testing requirement. Final decisions on these revisions are expected to be published by late summer.

I hope this information has clarified the application of the hearing conservation standard to the logging industry. If you have any additional concerns or questions, please feel free to contact me.


R. Leonard Vance, Ph.D
Health Standards Programs