OSHA Instructions STD 8.1 Sept. 15, 1980 Office of Compliance Programming

SUBJECT: Interpretation of Standards

A. Purpose. This instruction establishes a central source within the National Office to set policy and procedures for issuing standards interpretations.

B. Scope. This instruction applies OSHA-wide.

C. Cancellation. OSHA Program Directive #100 (Revision #1), March 10, 1975, is canceled.

D. Action.

1. Regional Office.

a. Regional Administrators shall provide interpretations of standards where the situation is clearly defined and not of National significance. When appropriate, they shall coordinate with the Regional Solicitor.

b. Regional Administrators shall assure that:

(1) No formal interpretation is issued in response to a request involving an employer who is contesting a citation without clearance from the Regional Solicitor.

(2) Requests for standards interpretations include all pertinent information such as a brief description of the operations and any other factors which prompted the request.

(3) An informational copy of any interpretation issued under provisions of paragraph D.l.a. is forwarded to the National Office, ATTENTION: Office of Compliance Programming.

OSHA Instruction STD 8.1 Sept. 15, 1980 Office of Compliance Programming

c. If the interpretation has significant impact nationally or is of controversial nature, the Regional Administrator shall forward the request to the National Office for action. In addition to basic pertinent data, with any referral include the recommendations from the field staff. If inspections, violations, variances or contests are involved, so note and include clarifying data as required.

2. National Office.

a. At the National Office level, the Office of Compliance Programming shall process all standards interpretations requests. This includes requests submitted according to paragraph D.1.c. and requests submitted from all other sources.

b. The Office of Compliance Programming is responsible for:

(1) Coordination, as appropriate, with the Directorates of Health Standards Programs, Safety Standards Programs and Technical Support, the Office of the Solicitor, the Office of Field Coordination and Experimental Programs and any other sources as required.

(2) Issuing instructions or notices in the OSHA Directives System, as appropriate.

c. All informational copies of interpretations which have been forwarded to the National Office under provisions of paragraph D.1.b. (3) will be reviewed by the Office of Compliance Programming for consideration as instructions or notices.

OSHA Instruction STD 8.1 Sept. 15, 1980 Office of Compliance Programming

E. Definition. "Interpretations" are explanations of standards and their workplace application, addressing scope and limitation, and any other questions which may arise regarding application to situations. Interpretations are not intended to change, modify or cancel standards.

Bruce Hillenbrand Acting Director, Federal Compliance and State Programs

DISTRIBUTION: National, Regional and Area Offices Compliance Officers State Designees NIOSH Regional Program Directors