March 1, 2004
Mr. David Williams
Chief Safety and Health Consultant
Occupational Safety and Health Associates, Inc.
1091 Cole Dr., S.W.
Atlanta, Georgia 30303
Dear Mr. Williams:
Thank you for your April 30, 2002 letter to Ms. Cindy Coe, Occupational Safety and Health Administration (OSHA) Regional Administrator (Atlanta, Georgia). Your letter was forwarded to the Directorate of Enforcement Programs for a response. 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 training requirements covered by 29 CFR 1910.268(c). I apologize for the delay in providing this response. Your paraphrased inquiries and our replies follow.
Question 1: What is OSHA's interpretation of "where appropriate" when related to the following standards and where would it apply:
Response: The requirement to provide training "where appropriate" allows employers to evaluate their own worksites and job tasks and determine for themselves, using reason and prudence, what training is necessary. We are aware that the nature of telecommunications work presents a wide variety of work locations, schedules, and work crew configurations.
- 29 CFR 1910.268(c)(1) Recognition and avoidance of dangers relating to encounters with harmful substances and animal, insect, or plant life;
- 29 CFR 1910.268(c)(2) Procedures to be followed in an emergency situation; and
- 29 CFR 1910.268(c)(3) First aid training, including instruction in artificial respiration?
For example, a crew working in a remote prairie or desert location may need to be trained, according to 1910.268(c)(1), in handling encounters with animal life, such as poisonous snakes, whereas a crew working in an densely populated urban area may not need the same training.
As with paragraph 1910.268(c)(1), paragraphs 1910.268(c)(2) and 1910.268(c)(3) also allow for training where the employer determines it is appropriate. The decision as to whether all employees covered by 1910.268 need to be trained in first aid and cardio-pulmonary resuscitation (CPR) would be made by the employer after assessing a variety of factors. It is the responsibility of the employer to evaluate the working locations, job functions, and potential hazards present. The employer must then determine what training content and method are most appropriate, based upon the most reasonable possibility for employee injury. The flexibility in the language of the standard allows employers to tailor their training program to their own particular needs and to the anticipated hazards of the work.
Question 2: How does 1910.268(c)(3) apply to installation technicians who "work alone," such as telephone installers, television mechanics, and communication mechanics?
Response: As stated earlier, the OSHA standard does not list specific circumstances under which employees must be trained. It is the responsibility of the employer to determine which employees would need this training based on an evaluation of the factors related to the job functions and related hazards. While an employee working alone would not have the opportunity to use his or her training on an injured co-worker, it is possible that training in first aid would be beneficial if an employee had to treat himself or herself for an injury. It would also help an employee determine if further medical attention from a health care provider was necessary.
Question 3: If OSHA requires first aid training for employees who "work alone," is cardio-pulmonary resuscitation (CPR) training also required also, in that they cannot perform CPR on themselves?
Response: Once again, it is not specifically required by OSHA that all employees covered by 1910.268, including those who work alone, receive first-aid and CPR training. The employer must prudently determine where such training is appropriate and which employees will receive the training. For example, it is possible that an employee who normally works alone may work with others during emergency restoration procedures or in other unusual, but foreseeable, circumstances.
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.
Richard E. Fairfax, Director
Directorate of Enforcement Programs