Purpose of field councils

The main purpose is to facilitate exchange of ideas and information throughout the Government about occupational safety and health. This is stated in 1960.84(a).

• Why this matters: councils create a structured forum for federal field offices to share best practices, lessons learned, training approaches, and coordinated responses to hazards.

The Secretary (through OSHA/agency leadership) will sponsor and/or provide guidance for existing field councils and establish new ones as needed. See 1960.84(b).

• Practical point: agencies should expect federal-level support or direction for setting up and running local field councils.

Field councils should consist primarily of qualified representatives of local area Federal field activities whose duties pertain to occupational safety and health, and also representatives of recognized local labor organizations or other civilian employee organizations at local area Federal field activities. See 1960.84(b).

• This means members typically include local safety officers, industrial hygienists, risk managers, and employee organization reps.

Yes. 1960.84(b) explicitly allows representatives of recognized local labor organizations, or other civilian employee organizations, to serve on field councils.

• Tip: agencies should identify locally recognized employee groups (beyond formal unions) when inviting participation.

Each agency provides the definition of "field activity" for the purposes of this subpart. See 1960.84(b).

• Practical step: agencies should document their internal definition of field activities (e.g., regional offices, field laboratories, contractor-managed sites) so council membership is clear.

No single mandatory requirement in 1960.84 forces every agency to have a council; rather, the Secretary will continue to sponsor and provide guidance for councils now established and will establish new field councils as necessary, per 1960.84(b).

• In practice: agencies covered by Part 1960 should coordinate with the sponsoring office to determine whether a local council is appropriate or required under agency policy.

1960.84(b) names representatives of local area Federal field activities and recognized local labor or civilian employee organizations; it does not explicitly list contractor employees as council members. See 1960.84(b).

• Note: civilian contractor employees performing work for federal agencies may be covered by OSHA standards in certain circumstances (see OSHA interpretation on applicability to Department of Defense facilities at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16). Agencies should clarify membership eligibility in their council charters.

Council members should be qualified representatives whose duties pertain to occupational safety and health, as stated in 1960.84(b).

• Examples of qualifying duties: developing safety programs, conducting hazard evaluations, implementing training, or managing injury and illness prevention efforts.

Yes. 1960.84(b) describes councils as consisting primarily of qualified representatives of local area Federal field activities; that language supports councils drawing representatives from multiple local federal field activities which may span agencies. See 1960.84(b).

• Practical use: cross-agency councils help align safety practices across nearby federal facilities.

Field councils should be used to facilitate the exchange of ideas and information across the Government about occupational safety and health, per 1960.84(a).

• Examples of information exchange: joint training schedules, incident investigation findings, hazard abatement strategies, and updates to local safety procedures.

Labor representatives bring the employee perspective and participate in the councils alongside qualified agency safety representatives, as allowed by 1960.84(b).

• Benefit: their participation helps identify workplace concerns employees experience and supports two-way communication about safety measures and training.

No. Field councils are forums to facilitate exchange of information and provide guidance, but they do not replace an agency's responsibility to operate its own occupational safety and health program under 29 CFR Part 1960. See 1960.84 and the broader Part 1960.

• Agencies must continue to meet their program obligations while using councils to coordinate and improve practices.

Yes. 1960.84(b) states the Secretary will establish new field councils as necessary, so councils may be created when local conditions or needs warrant it. See 1960.84(b).

• Recommendation: propose a new council when multiple local field activities would benefit from coordinated safety planning or when new hazards emerge.

The Secretary (through the sponsoring office) will continue to sponsor and provide guidance for councils now established and may modify or establish councils as necessary, per 1960.84(b).

• Action item: local councils should keep the sponsoring office informed of changing needs so higher-level sponsors can adjust support.

Military personnel and uniquely military equipment and operations are generally excluded from OSHA coverage, but civilian employees working on non-unique systems are covered; councils are intended for civilian federal field activities. See 1960.84(b) and the OSHA interpretation regarding civilian coverage in military facilities at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

• Practical implication: when forming councils in or around military facilities, agencies should identify which activities and employees are covered by federal safety rules and include only appropriate civilian representatives.

Field councils can facilitate discussion and exchange of technical information, but applicable OSHA standards and agency policies govern requirements for hazards like ventilation and respiratory protection; councils do not supersede those standards. See 1960.84 and the OSHA interpretation on respiratory/oxygen-deficient atmospheres at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

• Use councils to share problem-solving approaches and coordinate training, while applying the relevant OSHA standards to specific workplace decisions.

An agency should identify qualified local safety and health representatives, invite recognized local labor or civilian employee organizations, define the agency's "field activities," and coordinate sponsorship or guidance with the Secretary's designated office, consistent with 1960.84(b).

• Suggested checklist:
  • Document the agency's definition of "field activity."
  • Draft a council charter listing membership, meeting frequency, and objectives.
  • Coordinate sponsorship and guidance with the agency's central safety office.

No. While councils should consist primarily of qualified representatives whose duties pertain to occupational safety and health, they may also include representatives of recognized local labor organizations or other civilian employee organizations, per 1960.84(b).

• Inclusion of non-technical employee reps helps ensure worker concerns are heard and that communication is two-way.