Advisory committee meeting calls

Under 1912.25, only the Assistant Secretary or the Assistant Secretary’s representative designated for that purpose may call or give advance approval for an advisory committee meeting (1912.25).

• This means neither individual committee members nor outside stakeholders can unilaterally convene a committee meeting without that call or approval.
• If you’re unsure who the designated representative is, confirm with OSHA leadership or the Committee Management Officer before scheduling.

Under 1912.25, an advisory committee must have the meeting either called by, or have the advance approval of, the Assistant Secretary or his designated representative before it may meet (1912.25).

• "Advance approval" can be a formal decision or authorization from the Assistant Secretary or the designated representative; the regulation does not specify the format of that approval.
• Keep a record of the approval (email, memorandum, or official notice) to show compliance.

Under 1912.25, the Department of Labor’s Committee Management Officer must be promptly informed of any meeting that is called (1912.25).

• "Promptly" is not timed out in the rule, so notify the Committee Management Officer as soon as the meeting is authorized to avoid compliance questions.
• Practical practice: send the meeting notice and approval documentation to the Committee Management Officer immediately after the call or approval.

Under 1912.25, an advisory committee chair cannot call a meeting, even an emergency meeting, without the call or advance approval of the Assistant Secretary or the designated representative (1912.25).

• If urgent action is needed, contact the Assistant Secretary’s office or the designated representative immediately to request an expedited call or approval.
• Notify the Committee Management Officer promptly after approval is granted.

Under 1912.25, any meeting of an advisory committee—including subcommittees that are part of that advisory committee—may be held only at the call of, or with the advance approval of, the Assistant Secretary or his designated representative (1912.25).

• Treat subcommittee meetings as subject to the same approval rule unless a written delegation states otherwise.
• Inform the Committee Management Officer promptly whenever a subcommittee meeting is called.

Under 1912.25, the regulation requires that meetings be called or approved by the Assistant Secretary or designated representative but does not prescribe a specific form of documentation for that approval (1912.25).

• Best practice is to obtain and retain written or recorded proof of the call or approval (for example, an email, memorandum, or official notice) so the committee can demonstrate compliance.
• Also promptly share the approval and meeting notice with the Committee Management Officer.

Under 1912.25, the "representative designated for this purpose" is a person the Assistant Secretary has authorized to call or approve meetings on the Assistant Secretary’s behalf (1912.25).

• The regulation does not list names, so committees should confirm the identity and authority of any representative with the Assistant Secretary’s office or the Committee Management Officer before relying on that person’s approval.
• Keep a record of the designation or delegation when given.

Under 1912.25, the regulation requires that the Committee Management Officer be promptly informed of any meeting, but it does not explicitly state the legal consequences (such as invalidation) for failing to inform the Committee Management Officer (1912.25).

• Failing to inform the Committee Management Officer may be viewed as noncompliance with the procedural rule and could result in administrative follow-up; to avoid problems, inform the Committee Management Officer promptly after the meeting is called.
• If there is any question about the status of a meeting that proceeded without notice, consult OSHA or the Department of Labor’s Committee Management Officer for guidance.

Under 1912.25, the restriction on meetings applies to any meeting called by an advisory committee, regardless of format, so virtual meetings (teleconferences or videoconferences) require the same call or advance approval by the Assistant Secretary or designated representative (1912.25).

• Treat virtual meetings the same as in-person meetings for approval and for promptly informing the Committee Management Officer.
• Keep documentation of the approval and meeting notice for your records.

Under 1912.25, the Committee Management Officer should be informed promptly after a meeting is called or approved; the rule uses the term "promptly" but does not set a specific deadline (1912.25).

• Practically, notify the Committee Management Officer as soon as the meeting is authorized—ideally at the same time the meeting notice is circulated.
• Sending the meeting approval and agenda immediately minimizes the risk of noncompliance.

Under 1912.25, a committee must obtain a call or advance approval from the Assistant Secretary or the designated representative before meeting, and it should promptly inform the Committee Management Officer once approved (1912.25).

• Practical steps: (1) Contact the Assistant Secretary’s office or known designated representative with a written request that includes purpose, agenda, date/time, and participants; (2) obtain written or recorded approval; (3) notify the Committee Management Officer immediately and provide the approval and meeting notice; (4) retain copies of all approvals and notices for your records.
• If you don’t know the designated representative, confirm that person’s identity with OSHA leadership before scheduling.

Under 1912.25, outside parties or stakeholders cannot call advisory committee meetings; meetings may be held only at the call of, or with the advance approval of, the Assistant Secretary or his designated representative (1912.25).

• Stakeholders may request or propose meetings, but they must obtain the Assistant Secretary’s or designated representative’s approval before convening.
• After approval, promptly inform the Committee Management Officer and document the authorization.