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.

June 15, 1987

Mr. W. B. Treybig
Safety Engineer
Gulf States Road
Post Office Box 3785
Beaumont, Texas 77704

Dear Mr. Treybig:

This is in response to your letter of April 7 addressed to Mr. Charles Adkins, Director of Health Standards Programs. You inquired about the need to recertify your company's technicians who do the audiometric testing and pulmonary function testing that standard 29 CFR 1910.95, regulating occupational noise exposure, and standard [29 CFR 1926.1101] regulating asbestos, tremolite, anthophyllite, and actinolite exposure in construction work, respectively, require employers to make available to their employees.

The Occupational Safety and Health Administration (OSHA) defers to the certification retention rules of the accepted certifying groups. That is, OSHA adopts the given certifying group's position on the need for recertification. OSHA considers a technician to be certified as long as the certifying group recognizes the technician's certificate as valid. Conversely, OSHA would consider a technician whose certificate has expired to be not certified.

Thank you for contacting OSHA. We appreciate the opportunity to clarify this matter for you.


Leo Carey, Director
[Directorate of Enforcement Programs]

[Correction 6/2/2005]