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.


May 22, 1998

Frank R. Ciofalo, Deputy Chief
Department of Industrial Relations
Division of Occupational Safety and Health
45 Fremont Street, Room 1200
San Francisco, CA 94105

Dear Mr. Ciofalo:

Thank you for your letter of January 8, to Mr. Frank Strasheim, concerning posting the Occupational Safety and Health (OSHA) poster in portable carts or stalls. We acknowledge that in such worksites actual posting may not be feasible.

OSHA addresses posting notices, including the OSHA poster, in 29 CFR 1903.2. The issue is addressed both for establishments operating in states covered by Federal OSHA and for establishments operating in State-Plan states. When the business, conducted either from a business cart or vending stall, is supported by a central office to which employees report, 29 CFR 1903.2 states that all notices will be posted in a readily-visible location. Thus, we recommend posting the OSHA poster in the central office. When employees do not work at or report to a single establishment, 1903.2 states posters shall be posted at the location from which the employees operate to carry out their activities.

We trust that you will find the above helpful. If you have further questions, please contact this office again.


John B. Miles, Jr., Director
Directorate of Compliance Programs

[Corrected 10/22/2008]

45 Fremont Street, Room 1200
San Francisco, CA 94105

January 8, 1998

Frank L. Strasheim
Regional Administrator, Region IX
U.S. Department of Labor — OSHA
71 Stevenson Street, 4th Floor
San Francisco, CA 94105

Dear Mr. Strasheim:

The Division would like to know how Federal OSHA enforces the OSHA poster requirements in portable business carts or stalls where actual posting is not feasible; e.g., vending stalls in the aisle ways of a shopping mall, the employees only report at the stall, and there is no wall space at the stall for posting the OSHA poster.

Your assistance in this inquiry is greatly appreciated.


Frank R. Ciofalo, Ph.D.
Deputy Chief