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.

August 17, 1995

Mr. Dave Ortleib
Health and Safety Department
United Paperworkers International Union
P.O. Box 1475
Nashville, Tennessee 37202

Dear Mr. Ortleib:

This is in response to your letter of June 22, regarding batch digester safety in the paper industry. We regret the delay in responding to you.

As indicated in your letter, we have been contacted by paper industry representatives regarding interpretations of standards relating to batch digester safety. Theses representatives have requested a meeting on the subject; that meeting is now tentatively scheduled for October 10, to discuss technical issues. I hope that you will also be able to attend that meeting. I have asked members of my staff to keep you informed of any changes in the scheduled date, as well as the time and place.

Also, a copy of our correspondence with Mr. Richard P. Klinzing of the American Forest and Paper Association is enclosed for your information and background.

If you have questions about any of these matters, please feel free to contact Mr. Ray Donnelly or Ms. Alcmene Haloftis of my staff on 202-219-8041. If I may be of further assistance, please let me know.


Joseph A. Dear
Assistant Secretary