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 21, 1990

Mr. Bill K. Land
JWP Electronic Systems, Inc.
3656 Westchase Drive
Houston, Texas 77042

Dear Mr. Land:

This is in response to your letter of May 1, addressed to Mr. Joseph Pipkin of the Occupational Safety and Health Administration (OSHA), regarding a Nurse Call Communication System that is being installed in a major hospital by your company.

In your letter you described a "worst-case scenario" involving a patient, who might use the calling system and then be put in the AIDE NEEDED mode. The patient would then not be able to recall a nurse to report an emergency situation which might arise, while the calling system is in the AIDE NEEDED mode.

Under the Occupational Safety and Health Act (OSH Act), OSHA is responsible to make sure to the extent possible, that employers provide protection to their employees from workplace hazards. Since the situation you described in your letter does not pertain to employees' safety and health, it does not belong in OSHA's jurisdiction and therefore does not violate any OSHA requirements.

Normally, local governments have jurisdiction over such situations, and we suggest you contact the local county health department for further assistance. We also suggest that you contact the hospital administrator in this regard, so that alternative means of abatement, such as immediate response by the hospital staff to the patients' needs, may be implemented to correct the situation.

Thank you for your interest in safety and health. If we may be of further assistance, please contact us.


Patricia K. Clark Director
Designate Directorate of Compliance Programs