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OSHA 2200.6

Record address requirements

Subpart A

22 Questions & Answers
1 Interpretations

Questions & Answers

Under 2200.6(a), what information must every pleading or document filed by a party or intervenor include?

Every pleading or document must include the name, current address, telephone number, and email address of the party's or intervenor's representative or, if there is no representative, the party or intervenor's own name and those contact details. See 2200.6(a).

  • Provide a full name and at least one telephone number and one email address.
  • If you have an attorney or other representative, list the representative’s contact information rather than yours.

Cited: 2200.6(a).

Under 2200.6(a), what should a party do if they do not have a representative?

If a party has no representative, the party must list its own name, current address, telephone number, and email address on every pleading or document. See 2200.6(a).

  • This information must appear on each document you file so the Judge and other parties can contact you.

Cited: 2200.6(a).

Under 2200.6(a), how must a change in contact information be communicated and to whom?

Any change in the required contact information must be communicated promptly in writing to the Judge, or to the Executive Secretary if no Judge has been assigned, and to all other parties and intervenors. See 2200.6(a).

  • "Promptly in writing" means you should not delay — file or serve a written notice as soon as you know of the change.
  • If a Judge is assigned, send the written notice to the Judge; otherwise send it to the Executive Secretary and serve all other parties.

Cited: 2200.6(a).

Under 2200.6(a), what happens if a party or intervenor fails to furnish required contact information?

A party or intervenor who fails to furnish the required contact information is deemed to have waived its right to notice and service under these rules. See 2200.6(a).

  • Waiver means the party may not receive important filings, orders, or other notices and cannot later claim lack of notice as an excuse.

Cited: 2200.6(a).

Under 2200.6(b), what are the responsibilities of representatives, parties, and intervenors who file electronically in the Commission's E-File System?

Representatives, parties, and intervenors who file case documents electronically pursuant to 2200.8(c) are responsible for maintaining a valid email address associated with their registered E-File account and for regularly monitoring that email address. See 2200.6(b).

  • Keep the E-File account email current so you receive docketing notices and other electronic communications.
  • Regularly check that email; failure to do so can lead to missed notices.

Cited: 2200.6(b) and 2200.8(c).

Under 2200.6 and 2200.8(c), can a party update its contact information by filing a document through the E-File system?

Yes—filing a written document through the Commission's E-File system that states your new contact information satisfies the requirement to communicate the change in writing, and electronic filers must maintain and monitor the email associated with their account. See 2200.6(a) and 2200.6(b), with E-File authority at 2200.8(c).

  • Make sure the filing clearly states the changed address, telephone, and email.
  • Serve the same written update on all other parties and, where applicable, the Judge or Executive Secretary.

Cited: 2200.6(a), 2200.6(b), and 2200.8(c).

Under 2200.6(a), what does "current address" mean for contact information?

"Current address" means the party’s or representative’s accurate, up-to-date contact information (physical or mailing address), along with a telephone number and email address, so notices and service can reach them. See 2200.6(a).

  • If your physical address changes, update the record to the new address.
  • If you prefer mail at a PO Box or an office address, that is acceptable so long as it is accurate and you check it.

Cited: 2200.6(a).

Under 2200.6(a), can a party use a P.O. Box as its current address?

Yes, a party may use a P.O. Box as its current address so long as it is accurate and the party monitors that address; the regulation does not prohibit P.O. Boxes. See 2200.6(a).

  • Choose a contact method you will reliably check, because failing to receive mail may be treated as a waiver of notice.

Cited: 2200.6(a).

Under 2200.6(b), does failing to monitor an E-File email address count as failing to furnish required information?

Yes—if you file electronically, you are responsible for maintaining a valid email address and regularly monitoring it, and failure to do so can result in not receiving notice and may be treated the same as failing to furnish required contact information under the rules. See 2200.6(b) and 2200.6(a).

  • Keep your E-File account email current and check it frequently to avoid missing service or orders.

Cited: 2200.6(b) and 2200.6(a).

Under 2200.6(a), how soon must a change in contact information be reported — what does "promptly" mean?

You must report any change "promptly in writing," which means you should notify the Judge (or Executive Secretary if no Judge is assigned) and all other parties without undue delay after you learn of the change. See 2200.6(a).

  • Practically, act immediately or within a few business days after the change to avoid missed notices.
  • Use filing or service methods that generate proof of delivery when possible.

Cited: 2200.6(a).

Under 2200.6(a), if no Judge has been assigned, to whom must you send written notice of a change in contact information?

If no Judge has been assigned, written notice of any contact information change must be sent to the Executive Secretary and to all other parties and intervenors. See 2200.6(a).

  • Do not wait for case assignment; notify the Executive Secretary promptly in writing.

Cited: 2200.6(a).

Under 2200.6(a) and 2200.6(b), can an attorney’s firm email address be used as the required email address?

Yes—an attorney or representative may list the attorney's firm email address as the required email, but the filer remains responsible for maintaining that email address and regularly monitoring it. See 2200.6(a) and 2200.6(b).

  • If the firm changes email addresses or the attorney leaves the firm, promptly update the record in writing.

Cited: 2200.6(a) and 2200.6(b).

Under 2200.6(a), can a party use different contact information for service than for general contact?

The rule requires that every pleading contain the name, current address, telephone number, and email of the party or the party’s representative; if you want a different service address, include that specific service address in your pleading so it is clear to the Court and other parties. See 2200.6(a).

  • Clearly label any address that is intended for service to avoid confusion.

Cited: 2200.6(a).

Under 2200.6(b), what should you do if you permanently stop using the email address on your registered E-File account?

You must promptly update the registered E-File account with a valid email address and notify the Judge (or Executive Secretary) and all other parties in writing of the change; failing to maintain a valid monitored email risks missed service and waiver of notice. See 2200.6(b) and 2200.6(a).

  • Update the account immediately and serve the written notice to others.

Cited: 2200.6(b) and 2200.6(a).

Under 2200.6(a), does the requirement to include contact information apply to intervenors as well as parties?

Yes—intervenors, like parties, must include the name, current address, telephone number, and email address of their representative or, if unrepresented, their own contact information on every pleading or document. See 2200.6(a).

  • Intervenors must also promptly communicate any changes in writing to the Judge (or Executive Secretary) and all other parties.

Cited: 2200.6(a).

Under 2200.6(a), is the contact information requirement triggered only on the initial filing or on every document filed?

The requirement applies to every pleading or document filed by any party or intervenor, so each filing should include the required contact information. See 2200.6(a).

  • Including the information on each document reduces the risk that a filing will be ineffective because of outdated contact details.

Cited: 2200.6(a).

Under 2200.6(a) and the OSHA letter of interpretation (2004-09-27), are settlement agreements automatically posted on OSHA's public website?

No—OSHA's letter of interpretation explains that only major settlement agreements are posted on OSHA's public website, while most settlement agreements are not posted but remain subject to disclosure under the Freedom of Information Act. See the OSHA letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2004-09-27-0 and refer to 2200 for related procedural rules.

  • The letter clarifies that OSHA does post citations and proposed penalties and that archived News Releases are available on the website.
  • Even if not posted online, many settlement agreements can still be obtained via FOIA.

Cited: OSHA Letter of Interpretation: https://www.osha.gov/laws-regs/standardinterpretations/2004-09-27-0 and 2200.

Under 2200.6(a), what does it mean to be "deemed to have waived its right to notice and service" if contact information is not furnished?

Being "deemed to have waived its right to notice and service" means the party will be treated as if it consented to not receiving procedural notices and service under the rules because it did not provide required contact information. See 2200.6(a).

  • Practically, this can result in missing deadlines, orders, or hearings and losing procedural rights without the ability to later claim lack of notice.

Cited: 2200.6(a).

Under 2200.6(a), do intervenors follow the same prompt-written-notice rule when their contact information changes?

Yes—intervenors must promptly communicate any change in contact information in writing to the Judge (or Executive Secretary if no Judge has been assigned) and to all other parties, just like other parties. See 2200.6(a).

  • Failure to do so can be treated as a waiver of notice and service.

Cited: 2200.6(a).

Under 2200.6(b), what practical steps should electronic filers take to comply with the rule?

Electronic filers should (1) keep the E-File account email address current, (2) check that email regularly, and (3) promptly file or serve a written notice if the contact information changes. See 2200.6(b) and 2200.6(a).

  • Consider setting mail forwarding and automated alerts to ensure you receive E-File messages.
  • Use document filings that clearly state updated contact details and serve all parties and the Judge or Executive Secretary.

Cited: 2200.6(b) and 2200.6(a).

Under 2200.6(a), if a pro se party changes address, what must they do?

A pro se party must promptly communicate the change in their name, current address, telephone number, and email address in writing to the Judge, or to the Executive Secretary if no Judge has been assigned, and to all other parties. See 2200.6(a).

  • Failure to do so may be treated as a waiver of notice and service.

Cited: 2200.6(a).

Under 2200.6(a), does the rule require both a telephone number and an email address on filings?

Yes—the rule requires that every pleading or document contain a telephone number and an email address in addition to the name and current address of the representative or party. See 2200.6(a).

  • Provide working contact numbers and an email you actually monitor to avoid consequences for non-receipt of notices.

Cited: 2200.6(a).

Letters of Interpretation (1)