- Standard Number:
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.
April 4, 1995
Gerard Arrotti, C.I.H.
10 Skyline Drive
Hawthorne, New York 10532
Dear Mr. Arrotti:
Employee notification as covered under 29 CFR 1926.62(d)(8)(i) states in short that the employer shall notify each employee in writing of their results. The standard does not specifically address whether or not the notification can be posted or must be presented individually to each worker. In contrast, the construction asbestos standard allows either method of worker notification for the air monitoring results. Based upon what the asbestos standard accepts, written notification of employee airborne sampling results and the workplace exposure assessment for lead can be done individually or through a central posting. Since you mention posting the results and assessment on the union bulletin board, that would meet the specifics of the standard.
The second questions raised concerned identification of individual employees with the assessment posting. The standard requires that each employee shall be notified by the employer. To accomplish this, each affected worker would have to be able to identify their results. This could be done through using the employees name, social security number, other identifying number, or specific job title and work shift. OSHA would look to assure that any individually affected worker would be able to, without questions, identify their own monitoring results and exposure assessment.
We hope that this letter answers your questions. If you have any additional questions or concerns please give Richard Fairfax of my staff a call at (202) 219-8036. Your interest in occupational health and safety is appreciated.
Ruth McCully, Director
Office of Health Compliance Assistance
Ruth McCully, Director -
Office of Health Compliance
200 Constitution Avenue
Washington, D.C. 20210
Re: Request for Interpretation 1926.62(f)(8)(i)
Dear Ms. McCully:
Galson is an industrial hygiene consulting firm. A number of our clients have raised issues regarding the lead in construction standard. In particular, standard 1926.62(f)(8)(i) requires each employee to be notified in writing of the results of the exposure assessment within five working days. The standard also requires written notification be provided to employee's which the exposure assessment represents. Would posting the exposure assessment on a union bulletin board results meet the intent of the standard? If this is permitted, does the posting have to identify each employee whose exposure was represented individually by name?
Please provide a written interpretation of this standard. Your assistance in this matter is greatly appreciated.
Gerard Arrotti, CIH