To fully comply with OSHA requirements, you must understand the agency’s intent as well as letter of the law. Where there is a question on how to comply with a standard, EHS pros should take the initiative to obtain a letter of standard interpretation from the agency.
OSHA’s regulatory intent is found in the preamble to new/revised standards. For example, the preamble to OSHA’s revised March 26, 2012, HCS, “… provides a synopsis of the events leading up to the establishment of the final standard, a detailed description of OSHA’s rationale for the necessity of the modification, and final economic and voluntary flexibility analysis that support the Agency’s determinations.” Intent is the whole of the information within the preamble; particularly discussions regarding a stakeholder’s views and concerns.