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.

September 9, 1993

Mr. Neil E. Sherman, M.S.
Senior Industrial Hygienist
Compliance Services
4505 Highway 30
Ely, Iowa 52227

Dear Mr. Sherman:

This is in response to your letter of May 5, addressed to Ms. Patricia K. Clark, former Director of this office, and to the telephone communication with Mr. James C. Dillard of my staff, in which you requested an interpretation of "particular workplace" as used at 29 CFR 1910.165(b)(5), Employee alarm systems. We apologize for the delay in our response.

Specifically, you requested clarifications on whether the distribution of employees into the three structurally distinct work areas constitutes three "particular workplaces", and on whether the "10 or fewer" requirement of 1910.165(b)(5) applies when employees are distributed by way of "structurally distinct areas".

A "particular workplace" applies to an entirely separate building. Based on the particulars of your letter, and on the June 24, telephone conversation in which you stated that the "three separate buildings are tied together by a corridor or walkway", each one of the structurally separated buildings, with its own two means of exit, constitutes a "particular workplace". The distribution of employees as described in your letter constitutes three particular workplaces; therefore, the requirements of 1910.165(b)(5) apply separately to each of the three structurally independent buildings.

If you have additional questions, please feel free to contact Mr. Dillard.


Raymond E. Donnelly, Director
Office of General Industry
Compliance Assistance