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OSHA 1918.4

OMB information collection approvals

1918 Subpart A

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1918.4, what information does OSHA provide about information collection requirements in Part 1918?

Section 1918.4 lists which paragraphs in Part 1918 contain paperwork or information-collection requirements that have been approved by the Office of Management and Budget (OMB). The section identifies each 29 CFR citation and the OMB control number assigned to that collection, and it notes the control numbers' expiration dates where shown. See 1918.4.

Under 1918.4, which OMB control numbers and expiration dates are shown for the information collections listed?

Section 1918.4 shows two OMB control numbers and their expiration dates in the text: control number 1218-0196 (expires May 31, 2002) and control number 1218-0003 (expires July 31, 2001). See 1918.4.

Under 1918.4, how can I find whether a specific paragraph of Part 1918 contains an OMB-approved information collection requirement?

Section 1918.4 itself is the index: it identifies individual Part 1918 citations that contain OMB-approved information collections and lists the corresponding OMB control numbers. If a paragraph (for example, 1918.62(b)(1)) appears in 1918.4, it contains an OMB-approved information collection requirement. See 1918.4.

Under 1918.4, what does it mean when a citation such as 1918.62(h)(3)(ii) appears in the list?

If a citation like 1918.62(h)(3)(ii) is listed in 1918.4, that specific paragraph contains an information collection requirement that was submitted to and approved by OMB and assigned a control number. The listing in 1918.4 tells you that OSHA considers that paragraph to require some paperwork or recordkeeping subject to the Paperwork Reduction Act. See 1918.4.

Under 1918.66(e)(2), are crane hooks required to be latched or otherwise secured in longshoring operations?

Yes — crane hooks must be latched or otherwise secured to prevent accidental load disengagement where required by the standard. The longshoring standard explicitly requires that crane hooks be latched or otherwise secured in certain operations, and OSHA's letter of interpretation on safety latches confirms that whether a latch is required depends on the activity and that 1918.66(e)(2) requires latching or equivalent means. See 1918.66 and OSHA's interpretation on safety latches on sling hooks at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0.

Under 1918.97, does OSHA require employers in marine terminals and longshoring to have on-site individuals trained in first aid?

Yes — for marine terminals and longshoring operations, the standard requires employers to ensure one or more on-site individuals are trained in first aid where appropriate, and OSHA's interpretation on first aid and bleeding control explains how that requirement is applied and what "adequately trained" means for first aiders. See 1918.97 and OSHA's letter on first aid and bleeding control at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19.

Under 1918.62, does OSHA prohibit securing wire rope with knots in longshoring activities?

Yes — OSHA standards prohibit securing wire rope by knots in several industries, and the prohibition has been applied to longshoring via related standards; OSHA's historical interpretation explains that securing wire rope by knots is a recognized hazard and cites 1918.62 among the standards addressing the issue. See 1918.62 and OSHA's letter on wire rope knot prohibition at https://www.osha.gov/laws-regs/standardinterpretations/1977-12-14.

Under Part 1918 (for example 1918.85), does OSHA require employers to pay for personal protective equipment (PPE) provided to employees?

Yes — OSHA's final rule on employer payment for PPE requires employers to pay for PPE they provide in covered standards, including those that apply to Part 1918; OSHA's letter of interpretation explains that employers must not make employees bear the cost of required PPE and that deposit systems must not result in a net cost to the employee. See 1918.85 and OSHA's interpretation on employee PPE payment methods at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

Under 1918.66, can a crane operator leave the controls while a load is suspended if they become temporarily unable to operate?

No — an operator must be physically capable of performing the assigned task without unscheduled interruption that could affect safety; OSHA's interpretation about crane operator medical conditions explains that leaving the controls while a load is suspended is not acceptable. See 1918.66 and OSHA's letter on crane operator medical condition scenarios at https://www.osha.gov/laws-regs/standardinterpretations/2013-09-13.

Under 1918.4, if I see a paragraph (for example 1918.100(a)) listed with an OMB control number, where can I read the actual regulatory text that requires the information collection?

You should read the cited paragraph in Part 1918 itself because 1918.4 is only an index of information collections; the actual regulatory requirement and its text are in the cited section, for example 1918.100(a). See 1918.4 for the listing and the specific paragraph for the substance of the requirement.

Under 1918.4, what should an employer do if they need current information about a paperwork requirement's OMB approval or expiration?

An employer should consult 1918.4 to identify which paragraphs contain information-collection requirements and then check the current OMB listings or OSHA guidance to confirm the current control number and expiration status because 1918.4 provides the OMB control numbers and expiration dates as of the publication; for the standard text see 1918.4 and for the overall Part 1918 see 1918.

Under 1918.4, does the listing of a paragraph (for example 1918.64(k)(1)) in the table change the underlying safety obligations in that paragraph?

No — the listing in 1918.4 only indicates that the paragraph contains an OMB-approved information-collection requirement; it does not change the substantive safety or health obligations of the paragraph itself, which remain in the underlying regulatory text (for example, see 1918.64). See 1918.4.

Under 1918.4 and related guidance, how should letters of interpretation (for example about first aid or latches) be used when applying Part 1918 standards?

OSHA letters of interpretation explain how standards apply in particular situations and can clarify implementation, but they do not create new regulatory requirements; use them to understand OSHA's application of a standard (for example, see the first-aid interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19 and the safety-latch interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0) and read them alongside the actual regulatory text such as 1918.97 or 1918.66.

Under 1918.4, can the presence of an OMB control number in the list be used to find the specific paperwork an employer must complete?

Yes — the control number in 1918.4 points to an OMB-approved collection associated with the cited paragraph, but to find the exact form, format, or required entries you must read the cited regulatory paragraph itself and any OSHA guidance tied to it; start with the paragraph listed in 1918.4 and then consult the relevant section of Part 1918 (for example, 1918.62).

Under 1918.4, does an employer's obligation to follow a Part 1918 requirement depend on whether the OMB control number shown in the list has expired?

No — the employer's obligations flow from the regulatory text in Part 1918; 1918.4 simply reports which paragraphs have OMB-approved information collections and the control numbers/expiration dates as published. If you have questions about the current paperwork status (for example, whether an OMB approval has been renewed), confirm the active OMB control information through OSHA or OMB resources and continue to follow the underlying regulatory requirement in the cited paragraph (see 1918.4 and the specific paragraph in Part 1918).

Under 1918.66 and the OSHA letter on safety latches, when might a latch not be required on a hook used with slings?

A latch may not be required when the application makes the use of a latch impractical or unnecessary; OSHA's interpretation explains that whether a safety latch is required depends on the activity and that other positive means to secure the load may satisfy the standard, but you should follow 1918.66 and review OSHA's letter on safety latches on sling hooks at https://www.osha.gov/laws-regs/standardinterpretations/2006-01-10-0 for the agency's practical guidance.

Under 1918.61 and related listings in 1918.4, what does the inclusion of multiple subparagraphs (for example 1918.61(b)(2), (c), (f)(1), (f)(2), (g), (h), (i)) imply for compliance?

The inclusion of multiple subparagraphs of 1918.61 in 1918.4 indicates that several distinct parts of 1918.61 contain paperwork or recordkeeping elements that were submitted to OMB for approval. Employers must review each cited subparagraph in 1918.61 to identify the specific information-collection or recordkeeping duties applicable to their operations and follow those requirements as written.

Under 1918 (general), where can I find the complete longshoring standards referenced by 1918.4?

You can read the full text of the longshoring standards in Part 1918 on OSHA's website; the Part-level index is available at 1918, and individual sections (for example 1918.62 or 1918.66) contain the regulatory text that sets out employer duties.