Here’s How OSHA Inspectors “Interpret” OSHA Standards

January 4, 2013 Dave Weber No Comments

 

 

When browsing the on-line USA OSHA standards at www.OSHA.gov you may have noticed that some of the standards’ code numbers are colored blue, and others are black.  Ever wonder why there is this color difference?

All of the blue standard numbers are links that you can click on to find OSHA’s:

  • official interpretations of that particular standard
  • internal enforcement directivesthey have given to their inspectors instructing them how to enforce that standard in the field

This is more than just helpful information, you must know this if you intent to comply with how the OSHA inspectors are interpreting and enforcing a particular standard!

For example, let’s  go to the OSHA standard on first aidSection 1910.151(b) says -

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid.  Adequate first aid supplies shall be readily available.” 

This standard is not very specific and uses vague words such as “near proximity“, “adequately trained“, and “readily available“.   What specifically do these words mean and how is OSHA currently interpreting them?

Luckily, we find that “1910.151(d)” is colored blue.  If we click on 1910.151(b) we are taken to a new webpage that says there are 17 standard interpretations on this short, two sentence standard on first aid!

Click on the words standard interpretations.   You will now see the 17 interpretations and directives that the actual OSHA inspectors use when enforcing this standard in the field.   By clicking on interpretation #1 you will find that OSHA defines “near proximity” as – “emergency care that is no more than 3-4 minutes from the workplace. “

To fully comply with any OSHA standard you need to both understand the actual standard, and know how OSHA is interpreting and enforcing it! 

 

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