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OSHA 1952.27

Illinois State Plan approval

1952 Subpart B

14 Questions & Answers
2 Interpretations

Questions & Answers

Under 1952.27(a), when did the Illinois State Plan for state and local government employees receive initial approval?

The Illinois State Plan for state and local government employees received initial approval on September 1, 2009. This is stated explicitly under 1952.27(a).

Under 1952.27(c), which employers and employees does the Illinois State Plan cover?

The Illinois State Plan covers only State and local government employers and employees within Illinois. See the coverage statement in 1952.27(c).

Under 1952.27(c), does the Illinois State Plan cover private-sector or federal employees?

No — the Illinois State Plan does not cover private-sector or federal employees; it covers only State and local government employers and employees within the State of Illinois. The limited coverage is specified in 1952.27(c).

Under 1952.27(b), what staffing assurances did Illinois give when the Plan was approved?

Illinois assured that it would provide a fully trained, adequate staff within three years of plan approval, including 11 safety and 3 health compliance officers for enforcement inspections, plus 3 safety and 2 health consultants for public-sector consultation services. Those staffing details are listed in 1952.27(b).

Under 1952.27(b) and 1956.10, what is the state's ongoing obligation for enforcement staffing?

The State must continue to provide a sufficient number of adequately trained and qualified personnel necessary for enforcement of standards as required by 1956.10. Illinois gave assurance of this continuing obligation in 1952.27(b).

Under 1952.27(b), what personnel are designated for enforcement inspections and what do those roles mean in practice?

Illinois designated 11 safety and 3 health compliance officers to perform enforcement inspections. In practice, those officers will carry out inspections and enforcement actions for State and local government workplaces covered by the Illinois plan, as described in 1952.27(b).

Under 1952.27(b), what personnel are provided for consultation services and what do those consultants do?

Illinois designated 3 safety and 2 health consultants to perform consultation services in the public sector. Those consultants provide non-enforcement assistance such as hazard recognition, abatement guidance, and training support for state and local government employers as described in 1952.27(b).

Under 1952.27(b), what did Illinois assure about funding for the State Plan?

Illinois provided satisfactory assurance of adequate funding to support the State Plan. That assurance is explicitly stated in 1952.27(b).

Under 1952.27(b), what is the timeline Illinois set for having a fully trained, adequate staff?

Illinois committed to having a fully trained, adequate staff within three years of the Plan’s approval. This timeline is specified in 1952.27(b).

Under 1952.27(c), where can I find additional details about the Illinois State Plan?

Additional details about the Illinois State Plan are available through the Illinois State Plan web page referenced in 1952.27(c). The provision directs readers to the Illinois State Plan page for more information.

Under the Illinois State Plan coverage in 1952.27(c), are wastewater treatment employees who work for state or local government potentially covered by OSHA's Bloodborne Pathogens Standard?

They may be covered if their job tasks reasonably anticipate contact with blood or other potentially infectious materials (OPIM); coverage depends on the actual tasks and exposures. Employers must evaluate each job classification and task to determine whether occupational exposure exists, as explained in the OSHA interpretation "Bloodborne pathogens in wastewater" (2007) and consistent with the Illinois Plan coverage in 1952.27(c).

  • The OSHA letter explains that raw sewage and typical wastewater generally are not considered OPIM unless visibly contaminated with blood, so routine wastewater contact usually does not trigger the Bloodborne Pathogens Standard.
  • Examples that would trigger the standard include employees providing first aid involving blood or personnel who handle used hypodermic needles; those job duties require employers to follow 29 CFR 1910.1030 per the interpretation linked above.

If an Illinois state or local facility has a spray booth, do public-sector employers need to follow OSHA spray booth guidance?

Yes — if the structure meets the definition of a spray booth, public-sector employers in Illinois must comply with applicable OSHA requirements and enforcement procedures. The OSHA interpretation "Spray booth standards inquiry" (2004) explains how OSHA applies the spray booth rules to specific scenarios, and the Illinois coverage for public employers is specified in 1952.27(c).

  • The interpretation gives practical rulings such as when a structure meets the spray booth definition and when fire protection (e.g., sprinklers or approved alternatives) is required.

Under 1952.27(b), who enforces OSHA standards for the State and local government workplaces covered by the Illinois Plan?

Enforcement is carried out by Illinois’ compliance officers—specifically the 11 safety and 3 health compliance officers designated for enforcement inspections under 1952.27(b).

Under 1952.27(b), what assurance did Illinois give about the qualifications of its enforcement personnel?

Illinois assured that it would provide a fully trained and adequately qualified staff for enforcement, meaning the personnel would have the training and qualifications necessary to enforce occupational safety and health standards as required by 1956.10, and this assurance is stated in 1952.27(b).