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.
May 1, 1987
MEMORANDUM FOR THOMAS KOMAREK
Administration and Management
Occupational Safety and Health
|SUBJECT:||DOL Representation on the Interagency Committee on Seismic Safety in Construction|
The National Bureau of Standards (NBS) has drafted an Executive Order on Seismic Safety of Federal and Federally assisted or regulated construction. The NBS is a member of the Interagency Committee on Seismic Safety in Construction (ICSSC) in which the Federal Emergency Management Agency (FEMA) is the lead agency. The NBS proposal for and Executive Order requires Federal preparedness and activities to be implemented to reduce the risk to life and property from future earthquakes. When the Executive Order becomes final, each agency must implement its provision.
In a memorandum dated April 28, 1986 to Patrick Tyson, you requested that the Occupational Safety and Health Administration (OSHA) review the documents developed on seismic safety and designate an individual to serve as the Department's spokesperson and representative on ICSSC. The Directorate of Technical Support of OSHA has reviewed the seismic safety documents for technical accuracy from the safety and health aspects. However, OSHA has not selected a DOL representative to address departmental issues or to implement the Executive Order in the future.
Since the program is intended to reduce risk to the lives of occupants of buildings owned or used by the Federal Government, we believe that this task would be better handled in the DOL's Office of Safety and Health. Therefore, I suggest that you assign a DOL Seismic Safety Coordinator from the Office of Safety and Health to represent DOL on ICSSC and to implement the Executive Order when it becomes final. Since OSHA is the lead agency in occupational safety and health, OSHA provides Federal agencies with guidance necessary to implement effective safety and health programs, but OSHA does not administer such programs.
The following documents are attached for your action:
1. Seismic Design Guidelines for Federal Buildings prepared by ICSSC.
2. A letter from Mr. Richard Krimm, Chairman of the Interagency Coordinating Committee, to Mr. Raymond Kunicki, Safety Engineer, OSHA, regarding a project to prepare historic and baseline data on earthquake hazards reduction.
Thank you for your support.