Screen doors for temporary labor housing

September 22, 1998

Linda M. King, Administrator
Florida Department of Labor and
Employment Security
Division of Jobs and Benefits
Alien Labor Certification
[Recipient address omitted]
Dear Ms. King:

This is in response to your August 13, telephone conversation and facsimile to Helen Rogers of my staff in which you requested an interpretation of §1910.142(b)(8).

You also attached to your facsimile a copy of the Housing Inspection Check List from the H-2A Program Handbook, published by the Employment and Training Administration (ETA) of the U.S. Department of Labor, which asks: "Are all windows and outside doors equipped with screens (standard 16 mesh material) and is the screen door equipped with a self-closing spring or similar device?" You ask if §1910.142(b)(8) requires all external doorways in temporary labor housing to be provided with screen doors, and if the ETA interpretation of this provision is correct.

Section 1910.142(b)(8) of Title 29 of the Code of Federal Regulations reads as follows:

(8) All exterior openings shall be effectively screened with 16-mesh material. All screen doors shall be equipped with self-closing devices.

The first sentence of the above provisions clearly states that all exterior openings shall be effectively screened with 16-mesh material. An exterior doorway would be considered an "exterior opening." The second sentence just adds that all screen doors shall have self-closing devices. Therefore, this provision §1910.142 does require screen doors on all exterior door openings.

If you have any questions, contact Helen Rogers of my staff at (202) 219-8031 x107.

Sincerely,

Richard Fairfax, Acting Director
Directorate of Compliance Programs