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.

January 6, 1992

                        FEDERAL-STATE OPERATIONS

FROM:                    PATRICIA K. CLARK, DIRECTOR 

Subject:                 State of Washington Directive on Grain Handling

As requested by your memorandum of November 20, 1991, the subject directive has been reviewed for consistency with Occupational Safety and Health Administration (OSHA) Instruction CPL 2-1.4B, Grain Handling Facilities - Inspection Guidance and Standards Clarifications.

The content of the subject directive appears acceptable for providing inspection guidance and standards clarifications which are consistent with OSHA Instruction CPL 2-1.4B. Differences, other than organizational and regulatory references, are highlighted on the attached directive. Currently, OSHA Instruction CPL 2-1.4B is being reviewed for updating. A revised instruction is anticipated no later than the summer of 1992. One of the updates will be deletion of page 11 effective dates which have passed and no longer need to be referenced. The revised CPL 2-1.4C will include up-to-date inspection guidance and standards clarifications, particularly on problem areas which surfaced since CPL 2-1.4B was issued.