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Field sanitation coverage for agricultural hand labor

Summary OSHA revised its interpretation of which agricultural employers are covered by the field sanitation standard. It said coverage applies when an employer had 11 or more field hand-labor workers at any one time in the past 12 months, regardless of how workers are distributed among fields or how many are present on inspection day. The memo expressly rescinds four earlier interpretations, so agricultural employers should use this revised position.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-09-05
Date issued
September 5, 1989
Status
Active
Status last verified October 10, 2026
Topics
Workplace Safety OSHA 1928 Field Sanitation Agriculture
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

September 5, 1989

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

THOUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS

FROM: THOMAS J. SHEPICH, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Field Sanitation

This is to inform you of a policy change regarding the scope of coverage of the field sanitation standard. Effective immediately, the scope of coverage shall apply to any agricultural establishment/employer that has employed, during the past twelve months, at any one time, eleven (11) or more employees engaged in hand-labor operations in the field. This coverage applies regardless of the location(s) of the field(s) and regardless of the number of employees in any particular field or the number of employees engaged in hand-labor operations in the field on the day of inspection.

This change rescinds the interpretation found in the February 6 and 27 memorandums to Regional Administrators and in the January 31 and June 7 correspondence to Hi-Bred International, Inc. These interpretations were based on an erroneous reading of portions of the standard's preamble.

Please contact James C. Dillard, of my staff, at 523-8041, if you have additional questions.

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