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.
June 13, 1990
The Honorable Ron Marlenee
Member, United States
House of Representatives
111 5th Street North
Great Falls, Montana 59404
Dear Congressman Marlenee:
Thank you for your letter of May 2, addressed to Francis Duggan, former Assistant Secretary for Congressional and Intergovernmental Affairs, on behalf of your constituent, Mr. Stephen M. Peters. Mr. Peters is concerned about the hazards and regulations related to dry drilling operations.
Drilling operations directly related to mining procedures would normally fall under the jurisdiction of the Mine Safety and Health Administration (MSHA). Drilling operations related to oil, gas, and water wells normally fall under the jurisdiction of the Occupational Safety and Health Administration (OSHA). OSHA's Directorate of Safety Standards Programs has initiated action to develop a standard in these areas. As OSHA progresses toward the completion of this standard, the Agency will consider requirements for safety in dry drilling and for the use of water in drilling operations. Any additional information concerning hazards related to dry drilling operations would be helpful.
For your information, we have enclosed a copy of the Interagency Agreement between the MSHA and OSHA. This agreement is used as a guide in defining jurisdictional areas between the two agencies, and has been in place since 1979.
If we can be of further assistance, please do not hesitate to contact us.
Gerard F. Scanell
cc: Washington, D.C. Office