RFI stands for a “request for information.” These requests are an official form of communication that OSHA occasionally issues with the aim to receive feedback on the agency’s established standards. OSHA utilizes the expertise of professionals in the actual field or industry of the standard in question. A deadline is provided for employers to give feedback by, and once this information is gathered, OSHA uses it to make a decision on what steps to take next in order to effectively amend the standard.
RFI + Safety Standards
RFIs are one of the most useful ways to update standards. They’re also an essential tool to develop new strategies on successfully keeping employees safe in the workplace. The ultimate goal of issuing RFIs is to see how OSHA’s standards can be best used to fulfill safety needs as time goes on and new technologies are introduced. Most commonly, a request for information either expresses concern related to the efficiency of a standard, or it seeks further clarification of the official acceptance of certain safety practices.
For example, in May 2019, OSHA issued an RFI in connection with plans to amend its Lockout/Tagout standard, 29 CFR 1910.147. The agency asked for information in two areas where modernizing the standard would enhance worker safety, and it wanted to clarify the measures that provided efficient protection to employees who performed maintenance and service work. Professionals had the opportunity to help OSHA eliminate any uncertainty as well as educate the agency on the appropriate use of certain Lockout/Tagout technology.
For both OSHA and employers, the main challenge when it comes to requests for information is defining and authorizing the changes to be made in a way that is universally understood. If amendments will only cause further confusion (and put workers further at risk due to this miscommunication), OSHA would rather know now than later. Failure to weigh in once the RFI is released can also lead to complications for employers down the road; when professionals don’t engage in RFIs, the final outcome of the initiative may result in additional costs or other burdens they weren’t expecting. Ultimately, OSHA wants to ensure that their RFIs result in clarification that benefits the industry and enhances worker safety.
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