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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

Training requirements for employees doing occasional maintenance or repair work on a disposal site

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 18, 1990

Mr. Edward K. Wright
Safety Director
Anderson Equipment Company
Post Office Box 339
Bridgeville, Pennsylvania 15017

Dear Mr. Wright:

This is in response to your inquiry of June 11 concerning the application of training requirements in the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120) to employees doing occasional maintenance or service repair work on a disposal site.

Employees are not covered by the standard if they:

Training requirements for employees in food storage facility where ammonia is used solely as a refrigerant.

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 10, 1991

Mr. William Murray
Safety Coordinator
Christian Salvesen Inc.
One Enterprise Avenue
Secaucus, New Jersey 07094

Dear Mr. Murray:

Thank you for your inquiry of March 12, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.

Initial and annual refresher HAZWOPER training requirements for employees exposed to health hazards or hazardous substances at TSD facilities.

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.

March 7, 2007

Mr. Keith Gottsleben
Post Office Box 38
Gunpowder Branch
APG, EA, MD 21010-0038

Dear Mr. Gottsleben: