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.

January 29, 2004

Dr. Terje Ellingsen
Medical Officer
Qatar Fertiliser Company
PO Box 50001
Mesaieed - Qatar

Dear Dr. Ellingsen:

Thank you for your August 20, 2003 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding requirements for normal color vision and electricians. Your paraphrased inquiries and our responses follow.

Question: Are there any specific requirements for normal color vision for electricians or any other occupation in the United States?

Response: OSHA does not have any standards that require normal color vision for electricians or any other occupation. However, some industry consensus standards may have requirements for normal color vision. For example, the American Society of Mechanical Engineers standard, ASME B30.2-2001, Overhead and Gantry Cranes, states in paragraph 2-3.1.2 that operators of cab-operated and pulpit-operated cranes shall "be able to distinguish between colors, regardless of the position of colors, if color differentiation is required for operation." As you may know, consensus standards are voluntary guidelines, as they are not regulations promulgated by federal or state government. Also, some employers and vocational training programs may make normal color vision a condition of employment or enrollment if they determine that it is necessary to perform essential job functions safely.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. 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