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OSHA 2200.3

Use of singular and plural

Subpart A

12 Questions & Answers
1 Interpretations

Questions & Answers

Under 2200.3, can a singular word in an OSHA rule be read to mean more than one person or item?

Yes. Under 2200.3 words importing the singular number may be extended and applied to the plural, so a singular term can be read to cover multiple people or items when that makes sense in context.

  • This is a grammatical rule to help interpret regulatory text; it does not by itself create new duties beyond what the regulation requires. See also Part 2200 overview for the rules of procedure.

Under 2200.3, can a plural word be read to mean a single person or item?

Yes. Under 2200.3 words importing the plural may be applied to the singular, so a plural term can be interpreted to cover a single person or item when appropriate.

  • Use the common-sense meaning in context; the rule exists to avoid unintended gaps or overly rigid readings of the text.

Under 2200.3, does this singular/plural rule change the substantive requirements of an OSHA standard?

No. The singular/plural rule in 2200.3 is an interpretive guideline to help read regulatory language and does not itself add new substantive obligations or alter enforcement policy.

  • Enforcement decisions and penalty calculations are determined by the underlying standard and OSHA enforcement policies, not merely by grammar. For general procedural context see Part 2200.

Under 2200.3, how should I treat the word "employee" vs "employees" when applying an OSHA instruction to my workplace?

You should treat "employee" and "employees" as interchangeable when the context shows the rulemaker intended that, because 2200.3 allows singular words to be applied to the plural and vice versa.

  • Practically, if a requirement says "the employee must wear PPE" it can be read to mean all affected employees must wear PPE if that is the purpose of the requirement.
  • Always check the full regulation text and the hazard context to confirm how it applies in your situation.

Under 2200.3, can a citation written in the singular be used to cite multiple defective items found during an inspection?

Yes. Because 2200.3 permits singular terms to be applied to the plural, a citation phrased in the singular can be applied to multiple defective items when the facts support that application.

  • Inspectors must still show the violation element(s) for each cited condition; the grammatical number does not replace factual proof.
  • For procedural issues around citations generally, see Part 2200.

Under 2200.3, does the gender of a pronoun in a regulation limit who the rule covers (for example, "his" or "her")?

No. Under 2200.3 gendered pronouns do not limit application; singular/plural and pronoun forms should be read in context to cover the intended persons regardless of gender.

  • Modern interpretation practice treats gender-specific words as including all genders unless the regulation explicitly limits coverage.

Under 2200.3, when drafting company policies to comply with OSHA, should I mirror singular/plural forms exactly as written in the standard?

No. You should adopt language that clearly reflects the coverage you intend because 2200.3 only provides an interpretive bridge; clear company policy language reduces confusion for workers and inspectors.

  • Use plain, specific wording (e.g., "each employee" or "all employees affected") so there is no ambiguity about who must comply.

Under 2200.3, if a standard uses a collective noun (like "employer"), can it apply to multiple employers at a multi-contractor site?

Yes, where context shows the standard intends broader coverage, 2200.3 allows singular terms like "employer" to be applied in situations involving multiple employers.

  • However, legal responsibility among multiple employers depends on other principles (e.g., multi-employer doctrine), so review the specific standard and enforcement guidance in Part 2200 and relevant interpretive letters for how OSHA assigns responsibility.

Under the OSHA letter of interpretation dated September 27, 2004, are all historical citations and proposed penalties posted on OSHA's website?

Yes. The September 27, 2004 letter explains that OSHA posts citations and proposed penalties going back to the beginning of OSHA, and that historical news releases are available in the site archive, so much older material is available online.

Under the OSHA letter of interpretation dated September 27, 2004, can an employer ask OSHA to keep its settlement agreement confidential and off the website?

Not generally. The September 27, 2004 letter states that major settlement agreements are posted and most settlement agreements are not placed on the public web site, but they remain subject to disclosure under the Freedom of Information Act, so confidentiality cannot be guaranteed.

Under the OSHA letter of interpretation dated September 27, 2004, does OSHA remove older site content merely because it is more than 10 years old?

No. The September 27, 2004 letter explains OSHA does not remove material simply because it is older than 10 years; the agency posts records that would be available under FOIA and maintains an archive of news releases and other documents going back many years.

Under 2200.3, if a brief regulation uses the word "person," does that term include companies and organizations as well as individuals?

Often yes. Under 2200.3, the grammatical number rule supports reading terms like "person" to include entities the context indicates are intended, but you must check the specific standard to confirm whether "person" legally includes corporations or organizations.

  • When in doubt, consult the particular regulation's definitions and relevant guidance in Part 2200 to determine intended coverage.

Letters of Interpretation (1)