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OSHA 2200.106

Amendment to procedural rules

Subpart G

19 Questions & Answers
1 Interpretations

Questions & Answers

Under 2200.106, who may request that the Commission amend or revoke a rule?

Under 2200.106, the Commission may act on its own motion or any interested person may submit a written suggestion asking the Commission to amend or revoke a rule.

  • The provision explicitly allows the Commission to initiate changes itself and also accepts suggestions from "any interested person."
  • Suggestions must be written and should set forth reasonable grounds per the text of 2200.106.

Under 2200.106, how must I submit a suggestion to amend or revoke a rule?

Under 2200.106, you must send a written suggestion that sets forth reasonable grounds for the amendment or revocation.

  • The Commission invites suggestions to be emailed to rules.suggestions@oshrc.gov or mailed to the Executive Secretary at One Lafayette Centre, 1120 20th Street NW, Suite 980, Washington, DC 20036-3457.
  • The rule text specifies "written suggestion," so email and postal mail are acceptable formats per 2200.106.

Under 2200.106, does my written suggestion need to explain why the rule should be changed?

Yes. 2200.106 requires that a written suggestion set forth reasonable grounds for the requested amendment or revocation.

  • A short statement of the specific problem and the factual or legal reasons supporting the change will satisfy the "reasonable grounds" requirement.
  • The rule itself does not prescribe a form or length—only that reasonable grounds be stated in writing.

Under 2200.106, can the Commission change rules without receiving any public suggestions?

Yes. 2200.106 allows the Commission to amend or revoke rules on its own motion or initiative without receiving suggestions.

  • The text explicitly states the Commission may act "upon its own motion or initiative," so no outside suggestion is necessary for the Commission to begin an amendment.

Under 2200.106, does the Commission welcome suggestions from the public?

Yes. 2200.106 specifically invites suggestions from interested parties to amend or revoke rules of procedure.

  • The provision gives both an email address (rules.suggestions@oshrc.gov) and a mailing address for submitting suggestions, indicating the Commission encourages input.

Under 2200.106, is there a formal timeline or process listed for how the Commission handles a submitted suggestion?

No. 2200.106 authorizes amendment or revocation and invites suggestions, but it does not set out a formal timeline or detailed procedure for processing suggestions.

  • The rule states the Commission "may" amend or revoke rules based on suggestions but does not describe review steps, response deadlines, or notice procedures in the text of 2200.106 itself.

Under 2200.106, can suggestions be submitted anonymously?

The text of 2200.106 requires a written suggestion from "any interested person," but it does not expressly address anonymous submissions.

  • Because the rule asks for suggestions that set forth reasonable grounds, providing contact information is practical so the Commission can follow up if clarification is needed.
  • The rule itself does not forbid anonymous letters, but anonymity may limit the Commission's ability to verify or follow up on the suggestion.

Under 2200.106, can I propose that the Commission revoke a specific rule entirely?

Yes. 2200.106 explicitly authorizes the Commission to "amend or revoke any of the rules contained in this Part," so you may propose full revocation of a rule.

  • When proposing revocation, be sure your written suggestion sets forth reasonable grounds as required by 2200.106.

Under 2200.106, are suggestions limited to U.S. citizens or U.S.-based organizations?

No. 2200.106 simply refers to "any interested person" and does not limit who may submit suggestions by citizenship or location.

  • The rule contains no geographic or citizenship restrictions on who may submit a written suggestion.

Under 2200.106, what is the mailing address for sending a written suggestion to the Commission?

Under 2200.106, mailed suggestions should be addressed to the Executive Secretary of the Commission at One Lafayette Centre, 1120 20th Street NW, Suite 980, Washington, DC 20036-3457.

  • The rule also provides an email option (rules.suggestions@oshrc.gov) for convenience.

Under 2200.106, may I email a suggested amendment instead of mailing it?

Yes. 2200.106 invites suggestions and specifically provides the email address rules.suggestions@oshrc.gov as an option for submitting written suggestions.

  • Email submissions satisfy the "written suggestion" requirement stated in the rule.

Under 2200.106, does the rule say whether suggestions must follow a particular form or template?

No. 2200.106 requires only a "written suggestion" that sets forth reasonable grounds and does not prescribe any particular form or template.

  • Provide a clear statement of the rule you want changed, the exact amendment or revocation you propose, and the factual or legal reasons supporting that change to meet the rule's requirement for reasonable grounds.

Under 2200.106, if I submit a suggestion, does that document become public record?

2200.106 does not address public disclosure of suggestions, so whether a submitted suggestion becomes public depends on agency disclosure rules and applicable law (such as FOIA).

  • For related context on public posting of agency documents, see OSHA's interpretation explaining that materials like settlement agreements are generally public information and are subject to the Freedom of Information Act in OSHA's Letter of Interpretation (Sept. 27, 2004).
  • If you need confidentiality, consider noting any confidentiality concerns in your submission and consult the agency about nondisclosure procedures.

Under 2200.106, does the Commission have to give reasons when it amends or revokes a rule?

No specific requirement in 2200.106 prescribes that the Commission must provide reasons when it amends or revokes a rule; the provision simply authorizes amendment or revocation and invites suggestions.

  • Administrative practice or other parts of the Commission's rules may include notice-and-comment or explanation requirements, but those are not described in 2200.106 itself.

Under 2200.106, if I want to suggest a minor wording change, do I follow the same process?

Yes. 2200.106 covers amendments of any kind, so a written suggestion setting forth the reasonable grounds for a minor wording change may be sent by email or mail to the addresses provided.

  • Even small edits should explain why the change is needed and how it improves clarity or corrects an error.

Under 2200.106, can I ask that a rule be revoked because it is obsolete?

Yes. 2200.106 permits any interested person to submit a written suggestion to amend or revoke rules, and arguing that a rule is obsolete would be an appropriate "reasonable ground" to state in your suggestion.

  • Be specific about how the rule is obsolete and supply any supporting facts or references.

Under 2200.106 and related guidance, are settlement agreements with OSHA always posted online and public?

No. OSHA's guidance explains that while OSHA posts citations and many settlement agreements on its website, the majority of settlement agreements between OSHA and employers are not put on the web site, though they remain subject to disclosure under the Freedom of Information Act; see OSHA's Letter of Interpretation (Sept. 27, 2004).

  • The Letter of Interpretation notes OSHA posts major agreements but most settlement agreements are not posted online; however, they can still be obtained via FOIA.
  • The Letter also references the Commission's own rule that settlement agreements shall be posted in the same manner employers post citations (see discussion in the Letter of Interpretation).

Under 2200.106, may I propose changes to procedural rules that affect how settlement agreements are handled or posted?

Yes. 2200.106 allows interested persons to submit written suggestions to amend or revoke rules of procedure, which could include rules about settlement agreements and their posting.

Under 2200.106, if I submit a suggestion, who should I contact for a status update?

2200.106 does not specify a status-update contact, but it identifies the Executive Secretary as the Commission's point of contact for suggestions; you may contact the Executive Secretary at One Lafayette Centre, 1120 20th Street NW, Suite 980, Washington, DC 20036-3457 or use the provided email rules.suggestions@oshrc.gov per 2200.106.

  • Because 2200.106 does not lay out a formal timeline, direct inquiries to the Executive Secretary's office are the practical way to request a status update.

Letters of Interpretation (1)