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OSHA 1903.19AppC

Sample warning tag appendix

11 Questions & Answers
10 Interpretations

Questions & Answers

Under 1903.19AppC, is the Sample Warning Tag mandatory for employers to use?

No. Appendix C to 1903.19 is explicitly a nonmandatory sample warning tag and employers are not required to use it. See the sample tag described in 1903.19AppC.

Under 1903.19AppC, what information does the Sample Warning Tag show and how should it be used?

The Sample Warning Tag shows a brief, visible warning that equipment or an area has an OSHA-cited hazard and identifies the equipment and hazard with a pointer to the detailed OSHA citation. The sample tag's message includes fields such as "Equipment Hazard Cited by OSHA," "Equipment Cited:", "Hazard Cited:", and "For Detailed Information See OSHA Citation Posted at:" as shown in 1903.19AppC. Employers may use this tag as a quick, nonmandatory visual warning but must still comply with the formal citation-posting requirements in 1903.19.

Under 1903.19, can an employer use only the Sample Warning Tag in Appendix C instead of posting the full OSHA citation?

No. The Sample Warning Tag in 1903.19AppC is nonmandatory and does not replace the employer's duty to post the formal OSHA citation as required by 1903.19. The tag can be used in addition to the posted citation to warn workers, but the posted citation must comply with the regulation.

Under 29 CFR 1903.2 (posting of notice), is it compliant to hang the OSHA poster underneath or covered by other posters so that employees must move other materials to see it?

No. Employers must ensure OSHA notices are not altered, defaced, or covered and are displayed in a conspicuous place readily observable by workers; covering the OSHA notice so workers must move or uncover other materials does not meet the requirement. See OSHA's interpretation on poster display requirements in which OSHA explains that "covering OSHA notices with other documents ... does not meet the requirement or the intent of this standard" (OSHA poster display requirements, 2023-06-15).

Under 29 CFR 1903.2, can an employer display OSHA-required notices on a looping television monitor instead of posting physical copies?

No. OSHA requires notices to be readily available and accessible to employees at all times, and intermittent electronic display alone does not meet that requirement; employers should also post physical copies in a conspicuous location near the monitor. OSHA addressed this scenario and concluded that the method you described does not meet [29 CFR 1903.2(a)(1)] in the interpretation about electronic posting (Electronic posting requirements, 2014-11-05).

Under 1903.19AppC, are there color recommendations for the Sample Warning Tag?

Yes. The sample tag in 1903.19AppC uses an orange background with black message text (Background Color - Orange; Message Color - Black) to make the warning conspicuous; however, use of this color scheme is optional because the appendix is nonmandatory.

Under 1903.19, where must an employer post an OSHA citation and can a Sample Warning Tag satisfy that posting location requirement?

An employer must post the OSHA citation at or near the place where the violation occurred in a conspicuous location so employees can readily see it, and a Sample Warning Tag cannot substitute for that required citation posting. The formal posting obligation is set out in 1903.19, while the Sample Warning Tag is a nonmandatory visual aid in 1903.19AppC.

Under OSHA policy, if an employer files a timely notice of contest for a citation, will OSHA issue a second citation for the exact same condition while the contest is pending?

Generally no; OSHA normally will not issue an additional citation for the exact same condition, equipment, and location while that citation is under contest, but OSHA reserves the right to take enforcement actions (including seeking relief for imminent danger) if necessary to protect workers. OSHA explains this approach in its policy on contesting citations (Policy on contesting citations, 2023-09-11).

Under 29 CFR 1903.2, does an employer have to post the OSHA "You Have a Right to a Safe and Healthful Workplace" notice in Spanish if some or most employees speak Spanish?

No. The standard requires the OSHA notice to be posted in a conspicuous place but does not require posting in a foreign language; however, OSHA encourages employers with Spanish‑speaking workers to also post the notice in Spanish. OSHA explains this in its interpretation on poster language requirements (OSHA poster language requirements, 2004-11-12).

Under 29 CFR 1903.2, where should employers post the OSHA notice when workers operate from portable carts, vending stalls, or multiple remote locations?

When employees report to a central office, post the OSHA notice at that central office; when employees operate from locations where posting at a fixed wall is impractical, post the notice at the location from which employees carry out their activities or at the central point that supervises them. OSHA addressed posting in mobile or stall-type worksites and recommends posting at the central office or the location from which employees operate (OSHA poster posting requirements, 1998-05-22).

Under 29 CFR 1910.1020(g)(1), does routinely posting the OSHA poster satisfy the employer's obligation to notify employees about the existence and location of exposure and medical records?

No. Posting the OSHA poster does not satisfy the separate notification obligations in 29 CFR 1910.1020(g)(1) about the existence, location, and access rights for employee exposure and medical records; employers must inform employees specifically about those records and provide access on request. OSHA explains this distinction in its interpretation on employee exposure records notification (Employee exposure records notification, 2018-07-16).