Temporary labor camp rule and recreational camp counselors

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 6, 1975

MEMORANDUM TO: ALFRED BARDEN, ASSOCIATE ASSISTANT REGIONAL DIRECTOR/OSH
SUBJECT: Clarification of Standard 1910.142

This is in response to your memorandum dated June 30, 1975, requesting an official interpretation of the word "temporary," and the possibility the above mentioned standard could be used in covering paid camp counselors.
This office is in full agreement with Mr. Gilbert's pervious interpretation of the word "temporary" as stated in your letter of April 22, 1974, quote: "referred to the state of employment and not to the physical structure housing the employees."
As discussed recently with Mr. Garvey of your office, the National Office staff members of the Standard Development group have stated that it was not the intent of the ANSI Standard Committee for Z4.4-1968, source standard for 29 CFR 1910.142 temporary labor camps, to include recreational type camps under this standard. The general inference of this standard directs itself to employees engaged in farming, logging, and/or fruit or vegetable pickers. Therefore, the type camp mentioned in your correspondence would not fall under the 1910.142 standard. Of course in the case of a compliant, OSHA would have to investigate and cite alleged violations as in any normal complaint. It has not been OSHA's policy to inspect these camps, especially the non-profit organizations.
Barry J. White
Associate Assistant Secretary
for Regional Programs