- Standard Number:
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 1, 1991
MEMORANDUM FOR: FRANK STRASHIEM
REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Pacific Strike Force 24 Hour Training Requirement.
In the attached memorandum from Region VIII, it is reported that the USCG's Pacific Strike Force indicated 24 hours of training was required by OSHA for beach cleanup crews. While in certain operations this may be appropriate, fewer than 24 hours of training may be acceptable for other activity if the criteria in OSHA instruction CPL 2-2.51 is met.
We would like to request that Region IX coordinate with the Pacific Strike Force in order to minimize any ambiguity in regards to training requirements for post emergency response beach cleanup crews. Please notify Region VIII of the outcome.
We would also like to request that any correspondence on this matter be sent to the Office of Health Compliance Assistance for our files.
We hope this information is helpful. If you have any further questions please feel free to contact us at (202) 523-8036.
Attachment
March 22, 1991
MEMORANDUM FOR: PATRICIA K. CLARK
Directorate of Compliance Programs
THROUGH: LEO CAREY, DIRECTOR
Office of Field Programs
FROM: BYRON R. CHADWICK
Regional Administrator, VIII
SUBJECT: Regional Response Team Meeting
In response to your memo requesting feedback on OSHA's CPL 2-2.51, Inspection Guidelines for Post-Emergency Response Operations, under 29 CFR 1910.120, at a RRT meeting, we are providing the following information. During region VIII's recent RRT meeting, held in Denver, Colorado, 3/19 - 3/21/91, OSHA was given the opportunity to discuss our 1910.120 standard. The RRT participants response to this directive was overwhelmingly supportive.
However, a few questions/concerns were raised. Several concerns revolved around apparent inconsistencies in the application of this directive, particularly with State-plan OSHA states. At the recent oil spill scenario in California the Pacific Strike Force (USCG) indicated 24-hour training was required by OSHA for beach clean-up crews.
The USCG is confused and unhappy with Alaska's apparent initiation of an 80-hour training requirement for employees covered by OSHA's 1910.120 standard.
Some participants wanted further clarification between an initial emergency response and a post-emergency response with regard to an oil spill that flows further and further down a shore line. Is each new breach of a beach considered a "new" initial emergency response? Or is everything subsequent to the spill considered post-emergency response?
U.S.Department of Labor
Occupational Safety and Health Administration
1861 Stout Street
Denver, Colorado 80294
November 20, 1990
MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY, DIRECTOR
OFFICE FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS
SUBJECT: Regional Response Team Meeting
This is in response to a request made at the last meeting of the National response Team And Regional Response Team (RRT) co-chairs. OSHA RRT representatives have been asked to review OSHA Instruction CPL 2-2.51, Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120, at a RRT meeting.
Please attempt to get OSHA on the agenda for the next meeting.
We would be interested in your written comments on how the directive was received by the RRT.
Thanks for your cooperation.