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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.
MAR 19 1990
MEMORANDUM FOR: THOMAS J. SHEPICH, DIRECTOR
PATRICIA K. CLARK, DIRECTOR DESIGNEE Directorate of Compliance Programs
FROM: LEO CAREY, DIRECTOR Office of Field Programs
SUBJECT: Recommendations to Increase Availability of SAVES to the Field
I understand that DCP is in the process of finalizing nine new sets of SAVES, which are undergoing final proofreading. These SAVES address standards in 1910.110 - 1910.1200 and 1926.702. Based on the field's urgent and immediate need for this information, the IMIS Steering Committee has recommended to me that utilization of the VAX could save a great deal of time in the SAVES development/ publication process. I think that the committee's recommendations are worthy of serious consideration.
First, let me provide a little background to the IMIS Committee's recommendations. The Billings Area Office, as a part of the laptop pilot project, created a complete, corrected electronic version (Wordperfect/ASCII) of all of the existing SAVES that are currently resident on the Area Office microcomputers. A copy exists on the VAX which can be printed and provided to the Directorate of Compliance Programs or made available to Area Offices.
The IMIS Committee has suggested the following actions to accelerate the SAVES development/publication process:
1. An electronic copy of the final corrected version of the nine sets of new SAVES be provided to Salt Lake City (SLC) to be appended to the current repository of the Billings' electronic SAVES file;
2. This existing SLC SAVES file, then be added as a selection to OCIS so that it can be immediately available to the field;
3. As a one-time measure, a hardcopy of the new VAX-based SAVES database be provided to DCP and to each Regional and Area Office as short-term remedy to the field's immediate need for uniform, corrected SAVES;
4. Since there is now discussion about making OCIS OSHA's repository of compliance-related electronic information, the committee recommends that DCP and DTS look into the feasibility of establishing the following coordination during the SAVES development process:
a. DCP provide money to an existing contract with DTS for conversion of the SAVES Committee's written draft SAVES to electronic media at SLC for subsequent review and approval;
b. Changes resulting from internal OSHA reviews would be subsequently provided to SLC for electronic update;
c. When the final updates have been completed, mew SAVES could be released to the field via electronic media (either by direct downloading from the VAX, or on floppy disk). Subsequent hard copies of the new SAVES could be printed locally by the Area Offices/Regional Offices/State Offices, and provided to the field staff. Notices of all changes and additions to the SAVES file would be distributed automatically to the field at the same time new SAVES are added to the OCIS SAVES file.
I welcome any thoughts you have on these recommendations or any other suggestions you have to decrease the time required to develop and publish SAVES. Please feel free to call me. I am also providing a copy of this memorandum to OMDS to keep them apprised of our discussions in this area.