Displaying OSHA workplace safety posters

June 15, 2023

Lindsey Lopez, Founder

Compliance Organized, LLC

[Recipient address omitted]

Dear Lindsey Lopez:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA), requesting interpretation of the OSHA standard applicable to placement of OSHA posters and other government labor law posters on top of one another on a wall mounted hanger. This letter constitutes OSHA’s interpretation only of the requirements herein and may not be applicable to any questions not delineated in your original correspondence. Your paraphrased question and our response are below:

Question: Due to limited wall space, is it compliant for employers to hang OSHA posters and other labor law posters on top of one another on a wall mounted hanger if they are easily accessible and on display for all employees to view and access?

Response: No. 29 CFR 1903.2 (a)(1) states in part, "Each employer shall take steps to insure [sic] that such notices are not altered, defaced, or covered by other material." The intent of the standard is that the notice or notices are displayed in a conspicuous place and readily observable by workers. Accordingly, covering OSHA notices with other documents, regardless of the nature of those documents, and requiring workers to manually locate the OSHA notices does not meet the requirement nor the intent of this standard.

The State of California is one of the twenty-two states that administer their own safety and health program, which are overseen and monitored by Federal OSHA. State plan standards must be at least as effective as Federal OSHA standards, and the State may choose to promulgate and enforce requirements which are stricter than Federal OSHA's standards.

We recommend you contact the California State Plan regarding this issue as well. They may be reached at the following address and telephone number:

Cal OSHA Headquarters

1515 Clay Street, Suite 1901

Oakland, CA 94612

(510) 286-7000

Fax (510) 286-7037

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA's requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA's interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA's website at https://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Enforcement Programs at (202) 693-2100.

Sincerely,

Kimberly Stille, Director

Directorate of Enforcement Programs