Advisory committee roles

The National Advisory Committee's role is to advise, consult with, and make recommendations to the Secretary and the Secretary of Health, Education, and Welfare on matters relating to the general administration of the Act. See the requirement in 1912.5(a).

• This committee deals with broad, policy-level and administrative matters, not limited only to technical rulemaking.

Advisory committees under section 7(b) have a limited role: they assist the Assistant Secretary specifically in standards-setting functions under section 6 of the Act. See 1912.5(b).

• Practically, 7(b) committees focus on helping develop or review standards rather than advising on overall agency administration or broad policy.

The Advisory Committee on Construction Safety and Health helps both with standards-setting and with policy matters that arise in administering the Construction Safety Act. See 1912.5(c).

• When it gives general policy advice (beyond standards), its activities should be coordinated with the National Advisory Committee on Occupational Safety and Health.

No — advisory committees appointed under section 7(b) are not intended to advise on general administration; they are concerned exclusively with assisting the Assistant Secretary in standards-setting under section 6. See 1912.5(b).

• For general administration and broad policy advice, the National Advisory Committee under section 7(a) is the appropriate body (see 1912.5(a)).

Coordination is required when the Construction Committee renders advice to the Assistant Secretary on general policy matters; its activities on those matters should be coordinated with the National Advisory Committee. See 1912.5(c).

• This helps avoid conflicting policy recommendations and ensures consistent administration guidance across committees.

The National Advisory Committee formally advises the Secretary and the Secretary of Health, Education, and Welfare on matters related to the general administration of the Act. See 1912.5(a).

• That means its recommendations go to top officials responsible for broad oversight and administration.

It means 7(b) advisory committees provide expert help and recommendations to the Assistant Secretary specifically for developing, reviewing, or advising on standards under section 6, not on unrelated administrative matters. See 1912.5(b).

• Practical activities can include technical review of proposed rules, advising on feasibility or effectiveness, and suggesting language or evidence to support standards.

The Construction Committee can provide advice on policy matters related to the Construction Safety Act, but it does not itself set policy; its policy advice should be coordinated with the National Advisory Committee when it concerns general policy matters. See 1912.5(c) and 1912.5(a).

• Final policy decisions remain with the Assistant Secretary and the Secretaries who administer the Act.

No — section 7(b) advisory committees are described as assisting the Assistant Secretary in standards-setting and are not the body designated to make recommendations directly to the Secretary of Health, Education, and Welfare; that role belongs to the National Advisory Committee under section 7(a). See 1912.5(b) and 1912.5(a).

• In practice, 7(b) committees route standards-related input through the Assistant Secretary rather than directly to the Secretaries.

Overlaps should be managed by coordination: when the Construction Committee offers advice on general policy matters, it should coordinate its activities with the National Advisory Committee to avoid duplication or conflicting recommendations. See 1912.5(c).

• Coordination helps ensure consistent advice to the Assistant Secretary and the Secretaries and preserves clear roles for each committee.

Yes — advisory committees appointed under section 7(b) are described as being concerned exclusively with assisting the Assistant Secretary in standards-setting under section 6, which means their role should be limited to standards-related activities described in that section. See 1912.5(b).

• For other kinds of advice (administration or broad policy) the National Advisory Committee under section 7(a) is the appropriate forum (see 1912.5(a)).