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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.
September 16, 2008
Mr. John S. Ingram
ESIS Inc. - Global Risk Control Services
436 Walnut St, WA10B
Philadelphia, PA 19106
Dear Mr. Ingram:
