Connecticut State Plan Approval

The Connecticut State plan for State and local government employees received initial approval on November 3, 1978. See 1952.23(a).

• This date is the official initial approval recorded by OSHA for Connecticut's public employee-only plan.
• For the full text of the provision, consult 1952.23.

The Connecticut State plan covers only State and local government employers and employees within the State. See 1952.23(c).

• Private-sector employers and employees in Connecticut are not covered by this state plan; they remain under federal OSHA or the relevant authority for private-sector enforcement.
• For details and links about the Connecticut program, see 1952.23.

A State plan must have a sufficient number of adequately trained and competent personnel to carry out its responsibilities under the plan. See 1952.23(b) and 1956.10(g).

• This means the state must staff and train inspectors and program staff so they can perform enforcement, consultation, and other plan duties effectively.
• The requirement is programmatic: the State must be able to discharge its plan responsibilities, not simply list positions on paper.
• Connecticut's plan documents the staffing it used to meet this requirement; see 1952.23(b).

The Connecticut Public Employee Only State plan provided three (3) safety compliance officers and one (1) health compliance officer as set forth in the Connecticut Fiscal Year 1986 grant. See 1952.23(b).

• OSHA recorded that this staffing level met the "fully effective" benchmarks established for Connecticut for both safety and health at the time.
• The citation documents the historical staffing referenced in the approval notice; for current staffing you should consult the Connecticut plan office or current state documents.

No — being a "public employee only" plan means it applies only to State and local government employers and employees; it does not change the substance of applicable OSHA standards for those employers. See 1952.23(c).

• The plan implements OSHA-equivalent enforcement and standards for covered public employers within Connecticut.
• The plan's approval and staffing (e.g., as described in 1952.23(b)) are intended to ensure effective enforcement of those standards.

It means OSHA determined Connecticut's documented staffing (three safety officers and one health officer in the FY1986 grant) satisfied the benchmarks OSHA uses to judge whether a State plan is capable of fully carrying out its enforcement responsibilities. See 1952.23(b).

• "Fully effective" is a program evaluation benchmark used by OSHA when approving or renewing state plans.
• The approval notice records that, at the time of the cited grant, the State met the benchmark for both safety and health enforcement activities.

The State is responsible for ensuring it has enough adequately trained and competent personnel to perform the plan's obligations; OSHA requires this as part of plan approval and oversight. See 1956.10 and 1956.10(g).

• Practically, this means hiring, training, and maintaining staff capable of conducting inspections, consultations, recordkeeping, and enforcement actions.
• The Connecticut notice documents how the State met this requirement at the time; see 1952.23(b).

The official approval notice for Connecticut's plan is published in 1952.23. See that section for the approval date, staffing information, and coverage statement.

• For program details or current Connecticut state plan materials, the approval entry points you to the state plan resources referenced in the notice (the 1952.23 entry includes a link back to Connecticut program information).

OSHA's Bloodborne Pathogens Standard applies only when there is occupational exposure to blood or other potentially infectious materials (OPIM), and routine contact with diluted raw sewage generally does not meet that trigger. See the Bloodborne Pathogens letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2007-07-30.

• The letter explains that urine, feces, and typical sewage components are not treated as OPIM unless they are visibly contaminated with blood.
• Employers must evaluate job tasks and determine whether employees have reasonably anticipated exposure to blood or OPIM; if so, the standard applies to those employees (e.g., first-aid providers or staff exposed to used hypodermic needles).
• The interpretation provides examples and enforcement guidance for wastewater operations; see https://www.osha.gov/laws-regs/standardinterpretations/2007-07-30 for details.

Employers must offer the hepatitis B vaccine only to employees who have occupational exposure to blood or OPIM; if wastewater workers' duties do not reasonably anticipate exposure, the vaccine need not be offered. See the Bloodborne Pathogens letter at https://www.osha.gov/laws-regs/standardinterpretations/2007-07-30.

• The letter highlights that employers are responsible for evaluating job classifications and tasks to determine occupational exposure under 29 CFR 1910.1030.
• Examples where the vaccine would apply include employees who render first aid or who routinely handle used hypodermic needles; in those cases the employer must follow the hepatitis B vaccination provisions in the standard per the interpretation.
• Employers should document their exposure determinations and the basis for offering or not offering the vaccine.

Yes — based on the scenario described, the structure met OSHA's definition of a spray booth in 29 CFR 1910.107. See the spray booth letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-08-12.

• The interpretation analyzed a small-capacity power-ventilated structure used 1–2 times per week and determined it fit the spray booth definition given the described features.
• Once a structure meets that definition, the requirements of 29 CFR 1910.107 apply, including ventilation and fire-protection provisions referenced in the letter.

Yes — if a structure meets the definition of a spray booth, it is required to be equipped with approved automatic sprinklers on the upstream and downstream sides of the filters per 29 CFR 1910.107(b)(5)(iv), as explained in the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-08-12.

• The letter confirms that sprinkler protection applies to booths that meet the regulatory definition.
• The interpretation also notes allowable alternate fire-protection systems where they provide equivalent protection (see next question and the interpretation for details).

Yes — the interpretation states a dry chemical extinguishing system or a carbon dioxide system may be used in place of an automatic sprinkler system if it meets OSHA requirements and provides an equivalent level of protection. See https://www.osha.gov/laws-regs/standardinterpretations/2004-08-12.

• Dry chemical systems must meet the requirements of 29 CFR 1910.161 and gaseous agent (CO2) systems must meet 29 CFR 1910.162, as cited in the interpretation.
• Employers must ensure any alternate system is installed and maintained to provide equivalent fire protection for the booth's hazards.

The storage of flammable materials must meet the provisions of the flammable and combustible liquids standard, 29 CFR 1910.106, including specific design and construction requirements for inside storage rooms. See the spray booth letter at https://www.osha.gov/laws-regs/standardinterpretations/2004-08-12.

• The interpretation points to 29 CFR 1910.106(d)(4) for requirements such as maximum room size, ventilation, fire protection systems, and electrical wiring.
• Employers should consult 29 CFR 1910.106 for the detailed obligations applicable to paint storage rooms and ensure compliance.

State programs must maintain a sufficient number of adequately trained and competent personnel to discharge plan responsibilities, so Connecticut public employers or the plan office should adjust staffing, training, or contracting to ensure those capabilities are retained. See 1952.23(b) and 1956.10(g).

• Practical steps include documenting job duties, identifying training needs, recruiting qualified staff, and tracking competency and certifications.
• Any staffing changes that affect the State plan's ability to enforce standards should be coordinated with OSHA regional staff as required by plan oversight procedures.