Discretion in Enforcement when Considering an Employer's Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

April 16, 2020

MEMORANDUM FOR:

REGIONAL ADMINISTRATORS
STATE PLAN DESIGNEES

THROUGH:

AMANDA EDENS
Deputy Assistant Secretary

FROM:

PATRICK J. KAPUST, Acting Director
Directorate of Enforcement Programs

SCOTT KETCHAM, Director
Directorate of Construction

SUBJECT:

HAZWOPER refresher training and training documentation.

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 7, 1998

Paul W. Jonmaire, Ph.D.
Corporate Health & Safety Director
Ecology and Environment, Inc.
368 Pleasant View Drive
Lancaster, NY 14086

Dear Dr. Jonmaire:

This is in further response to your letter of march 4, 1998, concerning refresher training in accordance with paragraph (e)(8) of 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER). I apologize for the delay in responding to your letter.

Web-based HAZWOPER refresher training: hands-on training and trainer accessibility.

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.

October 20, 1999

Richard Chinn, MS, CET
President
Richard Chinn Environmental Training, Inc.
P.O. Box 10776
Pompano Beach, FL 33061-6776

Dear Mr. Chinn:

Whether a combination course can meet refresher training requirements in 1910.120(e)(8) and the OSHA 10-hour construction industry outreach program.

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.

July 17, 2008

Ms. Barbara McCabe, Program Manager
International Union of Operating Engineers
National HAZMAT Program
1293 Airport Road
Beaver, WV 25813

Dear Ms. McCabe: