Letters of Interpretation

OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Each letter constitutes OSHA's interpretation of the requirements discussed.

Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information.

These letters of interpretation and the standards they address may not apply to OSHA State Plans. State Plans are required to have standards and enforcement programs that are at least as effective as OSHA's and may have different or additional requirements. Please see OSHA-approved State Plans for more information.

NOTICE:

How to Request a Letter of Interpretation

Filters


Date Title Standard Number
Clarification on acceptability of National Environmental Trainers, Inc. (NET) interactive 40-hour training program. 1910.120
Training requirements for fire investigators. 1910.120, 1910.120(q)(6)
Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters. 1910.120(q)(6)(i), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
Whether a combination course can meet refresher training requirements in 1910.120(e)(8) and the OSHA 10-hour construction industry outreach program. 1910.120, 1910.120(e)(8)
Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER. 1910.120, 1910.120(e), 1910.120(e)(2)(i), 1910.120(e)(3)(i), 1910.120(q), 1910.120(q)(6)(iii), 1910.120(q)(6)(iii)(D)
Clarification of whether an employee can opt out of medical surveillance examinations under the HAZWOPER standard, 29 CFR 1910.120. 1910.120, 1910.120(f), 1910.120(q)(9), 1910.120(q)(9)(i)
Clarification of HAZWOPER training requirements as they apply to an employee of the town of Windsor, VT. 1910.120, 1910.120(a)(1), 1910.120(e), 1910.120(e)(1), 1910.120(e)(2), 1910.120(e)(3), 1910.120(e)(4), 1910.120(e)(9), 1910.120(q), 1910.120(q)(6)(ii)
Clarification of OSHA requirements for trainer qualifications under the HAZWOPER standard. 1910.120, 1910.120(e), 1910.120(e)(5)
Clarification of OSHA requirements for trainer qualifications under the HAZWOPER standard. 1910.120, 1910.120(e), 1910.120(e)(5)
Requirements for annual refresher training under OSHA's HAZWOPER standard. 1910.120(q), 1910.120(q)(6), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii), 1910.120(q)(8)
Requirement for employer to assess potential hazards of handling trailer debris to provide necessary PPE and hazard communication information to affected employees. 1910.120(q), 1910.132, 1910.134(a)(2), 1910.1200
Whether firefighters trained to the HAZWOPER awareness level can respond to emergency releases of hazardous substances. 1910.120, 1910.120(q), 1910.120(q)(6)
Initial and annual refresher HAZWOPER training requirements for employees exposed to health hazards or hazardous substances at TSD facilities. 1910.38, 1910.120(a)(1)(iv), 1910.120(e), 1910.120(p), 1910.120(p)(7), 1910.120(p)(8)(iii)
Applicability of HAZWOPER standard to hazardous waste generators that are not conditionally exempt as small quantity generators. 1910.120, 1910.120(a)(2)(iii), 1910.120(p)(8)
Applicable regulations when handling waste material classified as "sludge exempt" in regards to the Hazard Communication and HAZWOPER standards. 1910.120, 1910.120(a)(3), 1910.120(q), 1910.1200, 1910.1200(c)
Criteria for and training of the hospital Safety Officer per the requirements of the HAZWOPER standard and as discussed in the "Best Practices for Hospital-based First Receivers" guidance document. 1910.120(q)(3), 1910.120(q)(6)(ii), 1926.65
Acceptability of using computer-based (on-line) training for the HAZWOPER 40-hour classroom training. 1910.120, 1910.120(e)
Application of OSHA standards to escape and protection of employees from threats associated with terrorist actions. 1910.120(q), 1910.38
Application of HAZWOPER (1910.120) to terrorist and weapons of mass destruction incident responses. 1910.120, 1910.120(q)
Firefighter training requirements to respond to emergency releases, or potential emergency releases, of hazardous substance. 1910.120, 1910.120(q)(6)(ii)