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.

September 5, 1989

Dr. William H. McBeath
Executive Director
American Public Health Association
1015 Fifteenth Street, N.W.
Washington, D.C. 20005

Dear Dr. McBeath:

This is in response to your letter of August 9, to Secretary of Labor Elizabeth H. Dole, in which you requested that OSHA reconsider its interpretation of the scope of coverage provisions of the Field Sanitation Standard (29 CFR 1928.110).

OSHA has reviewed the basis of its interpretations of these provisions and finds that its earlier position was in error. For this reason, a new interpretation of the scope of coverage has been issued to Regional Administrators. A copy of the memorandum explaining the policy is enclosed for your information. Companies which received the erroneous interpretation will be notified.

We share your commitment to safe and healthful working conditions for all workers, and we appreciate your efforts to bring this problem to our attention. If we may be of further assistance, please let me know.


Alan McMillan
Acting Assistant Secretary