Martin v. Occupational Safety & Health Review Commission

Background

This dispute involved the Secretary of Labor, the independent Occupational Safety and Health Review Commission, and a steel company whose workers wore respirators that failed a fit test. A Labor Department compliance officer issued a citation and a $10,000 penalty under a rule requiring a respiratory protection program. An administrative law judge upheld the citation, but the Review Commission vacated it, saying the duty to assure individual respirator fit appeared in a different paragraph. The Court of Appeals sided with the Commission and deferred to the Commission’s reading of the regulations.

Reasoning

The Court addressed who should receive deference when both the Secretary and the Commission offer reasonable but conflicting interpretations of an ambiguous OSHA regulation. It concluded that Congress intended interpretive authority to follow the actor who both makes the rules and enforces them — the Secretary — because the Secretary drafts standards, handles enforcement, and gains broader experience with regulatory problems. The Court reversed the Court of Appeals, holding that a reviewing court may not prefer the Commission’s reasonable interpretation over a reasonable interpretation advanced by the Secretary. The Secretary’s interpretation, however, must itself be reasonable and is subject to ordinary judicial review.

Real world impact

The ruling gives the Labor Secretary primary authority to interpret OSHA regulations in enforcement matters, affecting how disputes over safety rules are resolved and limiting regulated employers’ ability to rely on the Commission’s contrary readings. The Supreme Court did not decide whether the Secretary’s interpretation was reasonable in this case; it sent the case back for the lower courts to evaluate the Secretary’s interpretation on remand. The decision is narrowly tied to the OSH Act’s split-enforcement design and does not decide how other agencies should be treated.