Updating OSHA directives

Last week, my time was spent preparing for the final stages of a process I’ve worked on for well over a year. I’ve been developing a directive, which is OSHA’s way of transmitting information to OSHA field offices across the country.

Directives are written for many reasons. Some of the information is routine and is sent frequently, for example, site specific targeting information. Other information may be very specific.

A directive not only serves as guidance to the field, but it also serves as guidance to employers. Employers may find directives useful for how to comply with a standard — especially in light of new technology.

When OSHA develops a directive, they first send it to the field offices for comments. The amount of time allowed for comment varies, depending upon the complexity of the document. Some directives involve multiple standards and issues, while other directives may just involve one aspect of a single regulation.

Once the comments are received, the national office staff assigned to complete the directive must address each comment. Each comment must be resolved in some manner. Sometimes this process can be finished quickly, while other times it may take years. Sometimes, a review commission decision or new technology impacts the directive while the comments are being resolved and causes re-evaluation of the directive.

And the process isn’t finished when the comments are finally resolved. The directive is put into a special format and sent to an OSHA administrator. The national office staff usually briefs the administrator on the directive and the possible impacts. Once the directive receives his approval, it moves to the policy planning board. This group ensures that the directive fits with the goals and strategic plan for OSHA and the Department of Labor.

Even after receiving the policy planning board’s approval, the process isn’t finished. The OSHA Training Institute, the Directorate of Enforcement Programs and any other relevant OSHA directorates develop training and/or outreach materials to educate both CSHOs and employers on the contents of the directive. Sometimes, clearance by other federal agencies may be necessary.

Of course, like any government agency, there are rules and procedures to follow. You can find these rules and procedures in their own directive. OSHA Instruction ADM 03-00-003 is the OSHA Directives System Directive, known as “The Directive on Directives.” You can find it at www.osha.gov .

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