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.
May 6, 1991
MEMORANDUM FOR: MICHAEL G. CONNORS REGIONAL ADMINISTRATOR FROM: PATRICIA K. CLARK, DIRECTOR DIRECTORATE OF COMPLIANCE PROGRAMS SUBJECT: Favorable Review Commission Decision - Secretary of Labor v. Keefe Earth Boring Company, Inc. (KEBCO), Docket No. 888-2521
The Review Commission affirmed Administrative Law Judge Salyers' decision on March 25, 1991. Judge Salyers had originally denied KEBCO petition for relief from several final orders. The root of KEBCO defense was their claim that they did not understand that the citations would become a final ruling of the Commission 15 days after issuance.
The attached copy is for your information and reference, if further litigation results from this decision.