Who We Are
Nov 22, 2000
Baruch A. Fellner, Esq.
Lawrence P. Halprin, Esq.
Re: Clarification of Compliance Deadlines: Final Ergonomic Standard
Dear Messrs. Fellner, Sparlin, Halprin & Sarvadi:
This is in response to your letter of November 20 to Joseph Woodward, Associate Solicitor. Mr. Woodward has referred your letter to me because it asks for an interpretation of an OSHA standard, the ergonomics Program rule, 29 CFR 1910.900. You ask whether employers have compliance obligations before October 15, 2001.
Employers have no compliance obligations under the standard until October 15, 2001. By that date, employers must provide the information described in paragraph (d) to their employees. 29 CFR 1910.900(x)(1). After October 15, 2001, employers must respond to employee reports of MSDs and MSD signs and symptoms in accordance with the time frames set forth in Table W-2. 29 CFR 1910.900(x)(2). None of the obligations referred to in Table W-2 take effect before that date. Rather, the purpose of the Table is to set forth the compliance time frames that apply with respect to reports made after October 15, 2001.
Charles N. Jeffress