MEMORANDUM FOR A1 - Air Force E-Publishing

76 AFI91-202 5 AUGUST 2011
8.7.3. Military-Unique Situations. OSHA standards do not apply to military-unique
workplaces, operations, equipment and systems. However, Air Force policy is that OSHA
standards shall apply as much as possible, practicable and consistent with military
requirements, unless HQ AFSC approves an exemption or variance.
8.7.4. Variances and Exemptions. The affected work center shall process a request for
variance when it is impractical or impossible to meet OSHA Standards or AFOSH guidance
due to operational needs, mission impact or technical reasons. Variances are temporary and
are normally granted for periods not to exceed five years. Exemptions grant permanent relief
from a requirement and can be approved when the applicant can substantiate that their
proposed methods, equipment or facilities protect the worker as well or better than the
AFOSH or OSHA Standards. AFSC may grant exemptions or variances to AFOSH
Standards and guidance that are more stringent than OSHA requirements. AFSC does not
have the authority to grant a waiver or exemption to an OSHA Standard. Only OSHA can
grant waivers or exemptions to Title 29 (OSHA) requirements (even if included in AFOSH
Standards). However, for safety related issues, AFSC will serve as the liaison between
OSHA and the Air Force requestor. NOTE: A unit’s inability to fund corrective actions does
not constitute sufficient justification to request a variance. Request extensions for variances
through MAJCOMs to HQ AFSC/SEG.
8.7.4.1. Variance/Exemption Process.
8.7.4.1.1. Affected work center personnel shall implement interim control measures
and notify the installation ground safety, fire or health officials to validate the
effectiveness of interim controls. With effective controls in place, the work center
will coordinate the variance/exemption package with installation ground safety, fire
and health officials.
8.7.4.1.2. The installation safety office will assemble a detailed staff package that
identifies the request, rational why the standard cannot be followed, interim control
measures, drawing, maps, etc. (see paragraph 8.7.4.2), and forwards the request to
MAJCOM headquarters through appropriate command safety, fire or health channels.
8.7.4.1.3. The MAJCOM safety staff reviews and, if recommended for approval,
forwards requests to AFSC/SEG (safety-related issues), AFCESA/CC (fire
prevention-related issues) or AFMOA/SGO (health-related issues), as appropriate, for
final approval. NOTE: Requests received without MAJCOM coordination will be
returned to requestor without action.
8.7.4.1.4. The MAJCOM/installation ground safety manager maintains a master file
of approved variances or exemptions that apply to the installation/MAJCOM/AF as
long as they are in effect and for one year thereafter. The safety manager distributes
copies of variances and exemptions to fire protection, health and functional managers,
as needed.
8.7.4.1.5. Functional managers must train affected employees and employee
representatives on approved variances, exemptions or any special procedures required
and document training. Post copies in affected work areas until integrated into the
JST guide.
8.7.4.2. Written variance or exemption requests must contain: