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.

September 6, 1990

MEMORANDUM TO:      PATRICIA CLARK, DIRECTOR
                   DIRECTORATE OF COMPLIANCE PROGRAMS

FROM:               ROGER CLARK, DIRECTOR 
                   DIRECTORATE OF SAFETY STANDARDS PROGRAMS

SUBJECT:            REQUEST FOR CLARIFICATION ON 29 CFR 1910.165

At the request of the Safety Compliance office we have become involved in a review of a request for clarification for 29 CFR 1910.165, Employee Alarm Systems. The request was initiated by GAI-Tronics Corporation of Houston, TX through the Dallas Regional Office.

Without answering each of GAI-Tronics questions, the basic goal of 29 CFR 1910.165 is that the employer provide, when required, an alarm system that will give all employees at the worksite adequate warning to the danger that the alarm signifies. This means all employees, including those with physical impairment, must be able to perceive and recognize an alarm signal for the purpose that it is sounded. Employees must have the proper training to identify alarm signals for what the alarm means and to know what their duties and responsibilities are when the alarm sounds.

One important fact to remember is that 29 CFR 1910.165 only applies to those alarm systems that are required by other OSHA standards. It does not apply to all alarm systems in the industrial environment. The purpose of this limited application is to assure that the OSHA alarm standard is limited to those alarm systems installed to meet a specific OSHA standard for employee safety. We are not regulating alarm systems that are used for other purposes.

We believe that the Agency's formal response to GAI-Tronics should come from your office since it could impact other alarm system installations throughout the Nation.