Standard Interpretations - Table of Contents
• Standard Number: 1928

May 22, 1990

Salvador Sandoval, MD
Merced Family Health Center
Post Office Box 858
Merced, California 95430

Dear Dr. Sandoval:

Thank you for your letter of April 13, in which you referred to your productive March 13 meeting with Dr. Monahan and two staff members of the Directorate of Compliance Programs. You also expressed your concern with the Occupational Safety and Health Administration's (OSHA) interpretation of the Field Sanitation Standard, particularly as it relates to the number of workers excluded from coverage. In addition, you stated that there were serious problems with enforcement of the standard, and that your clinic will conduct a survey of migrant clinics this summer to determine the extent of the enforcement problem with respect to the Field Sanitation Standard.

We share your commitment to safer and healthier working conditions for agriculture employees. Thank you for visiting with us and expressing your views. As my staff members informed you, OSHA is in the process of reviewing several aspects of the Field Sanitation Standard, including its scope of coverage provision. As you may be aware, OSHA's enforcement jurisdiction is limited to farms with 11 or more employees, except where farms have temporary labor camps. Our most recent (September 5, 1989) interpretation of the scope of coverage provision of the standard, enclosed for your information, is still in effect. This compliance memorandum, as you can see, clearly does not exclude or limit employee coverage below that of the Field Sanitation Standard. Should there be a change in this interpretation, it will be addressed in the upcoming compliance program directive.

Thank you for the copy of the September 19, 1988, news clipping that contained an interview with OSHA's Region IX Administrator, Frank Strasheim, in which he discussed the Agency's field sanitation activities in California. Mr. Strasheim was