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.

June 19, 2000

Ms. Barbara Markland
Administrative Secretary
Leesburg Department of Parks and Recreation
50 Ida Lee Drive, N.W.
Leesburg, Virginia 20176

Dear Ms. Markland:

Thank you for your April 6, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) Office of Public Affairs. You requested information regarding OSHA requirements as they relate to sun exposure to employees. Specifically, the type of sun screen to be used, protective sunglasses, hats, clothing, etc.

The Occupational Safety and Health Administration does not specifically address worker exposure to solar radiation. 29 CFR 1910.132(a) pertaining to personal protective equipment, indirectly would require employers to provide appropriate personal protective equipment to prevent exposure to serious hazards.

Please note that Section 18 of the OSH Act encourages States to assume responsibility for their own occupational safety and health programs under a plan approved and closely monitored by Federal OSHA. The Virginia Department of Labor is operating such a plan and is responsible for the enforcement of its own occupational safety and health standards and the investigation of workplace complaints throughout the State. All of Virginia's job safety and health standards, including interpretations, are identical to or at least as effective as the comparable federal OSHA standards.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may wish to consult OSHA's website at
http://www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement] at (202) 693-1850.

Sincerely,

Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 6/2/2005]