Use of feasible engineering/work practice controls for exposure to Cr(VI) for welding in confined spaces; housekeeping and disposal of large/bulky waste materials.

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 31, 2007

Kathryn M. McMahon-Lohrer, Esquire
Kelley Drye Collier Shannon
Washington Harbour, Suite 400
3050 K Street, NW
Washington, DC 20007-5108

Dear Ms. McMahon-Lohrer:

Review of Manual for training personnel engaged in oil spill emergency response.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

December 27, 1994

Don A. Alberts, Ph.D. All Points Associates, Inc. World-Wide Environmental and Safety Consultant Firm 3309 Peru Center Road Monroeville, Ohio 44847-9799

Dear Dr. Alberts:

Construction of aboveground storage tanks and confined space; §§1926.21(b)(6) and 1910.146; General duty clause

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 10, 2006

John E. Williams III
Pasadena Tank Corporation
15915 Jacintoport Boulevard
Houston, TX 77015

Dear Mr. Williams:

This is in response to the January 18, 2006, letter you sent to the Occupational Safety and Health Administration, inquiring about the applicability of confined space requirements to aboveground storage tank construction. We apologize for the delay in our response.

We have paraphrased your questions as follows:

Whether reclassification is available for permit-required confined spaces with potentially hazardous atmospheres.

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.


August 6, 2007

Mr. Ken Wilcoxson
945 Calle Del Encanto
Las Cruces, NM 88005

Dear Mr. Wilcoxson:

Thank you for your September 19 letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry Enforcement (GIE) regarding an interpretation of 29 CFR 1910.146, the Permit-required confined spaces (PRCS) standard. Your scenario, diagram, and questions have been restated below for clarity.

PRCS and LOTO requirements for accumulation of stored energy in steam pits

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 18, 2007

Mr. Mark A. Gintner
COMTEC International, Inc.
P.O. Box 7184
Kennewick, WA 99336-0616

Dear Mr. Gintner:

Applicability of the PRCS standard to aircraft maintenance activities.

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.

 

Determining whether an aircraft fuel tank is considered a confined space.

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 5, 2008

Mr. Andrew Lewis
Safety Manager
Sierra Nevada Corporation
18635 Jarkey Drive
Hagerstown, Maryland 21742

Dear Mr. Lewis:

Thank you for your July 17 letter to the Occupational Safety and Health Administration (OSHA). Your letter has been referred to OSHA's Directorate of Enforcement Program's (DEP) Office of General Industry Enforcement. Your scenario and question has been restated below for clarity.

Employer selection of local fire department as its off-site rescue service for compliance with 29 CFR 1910.146(k)(1).

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 23, 2008

Mr. Jonathan L. Pennington
McCulley Eastham & Associates, Inc.
P.O. Box 320
Greenup, KY 41144

Dear Mr. Pennington:

Thank you for your January 2 letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). Your letter has been referred to DEP's Office of General Industry Enforcement (GIE) for an answer regarding OSHA's Permit-required confined spaces standard (PRCS), 29 CFR 1910.146.

Clarification of OSHA training requirements for basic first aid and cardiopulmonary resuscitation (CPR).

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.

August 2, 2012

Mr. Ralph M. Shenefelt
Vice President, Strategic Compliance
Health and Safety Institute
1450 Westec Drive
Eugene, Oregon 97402

Dear Mr. Shenefelt:

Building and Construction Trades Department - 04/06/2007

 

IN THE UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT

BUILDING AND CONSTRUCTION
TRADES DEPARTMENT, AFL-CIO,
LABORERS' INTERNATIONAL
UNION OF NORTH AMERICA, and
INTERNATIONAL BROTHERHOOD
OF TEAMSTERS,

Petitioners,

v.