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.

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How to Request a Letter of Interpretation

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Date Title Standard Number
Inspection Guidance for Animal Slaughtering and Processing Establishments 1903.8, 1904, 1910 Subpart E, 1910.95, 1910.111, 1910.119, 1910.132, 1910.141, 1910.147, 1910.212, 1910.1000, 1910.1200, 1913.10
Storage of pre-charged air conditioners and heat pumps in warehouses or distribution centers 1910.119(a)
Sulfur sticks and hot work requirements 1910.119(k)
Clarification on terms used in OSHA's PSM standard 1910.119
Employer Responsibilities and Contractor Responsibilities under the PSM Standard 1910.119(h)(2)(vi), 1910.119(h)(3)
PSM Coverage of LNG Facilities 1910.119
OSHA PSM and Explosives Standards as They Relate to the DOT Classification "Not in the Explosive Class" 1910.109, 1910.109(a), 1910.109(k), 1910.109(k)(2), 1910.109(k)(3), 1910.119, 1910.119(a)
Documentation of PHA Findings and Recommendations 1910.119(e)(5), 1910.119(e)(7)
Discretion in Enforcement when Considering an Employer's Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic 1910.95(g)(6), 1910.119(e)(6), 1910.120(e)(8), 1910.120(p)(7), 1910.120(q)(5), 1910.120(q)(7), 1910.134(f)(2), 1910.134(k), 1910.1048(l)(4), 1919.15, 1926.1412(f)
Updates to PHA Extended Shutdown Facility 1910.119(e)(6)
PSM and Aerosol (Flammable Gas) Containers Stored in Warehouses/Distribution Centers 1910.119, 1910.119(a), 1910.119(d)(3)(ii)
Production facilities that recover natural gas liquids may have enforceable PSM-covered processes 1910.119, 1910.119(a), 1910.119(b)
Flammable Liquid Processing Letter 1910.106, 1910.119
Memorandum to Regional Administrators – Process Safety Management Retail Exemption Enforcement Policy 1910.119
What constitutes an emergency response or incidental release of anhydrous ammonia 1910.38, 1910.119, 1910.120, 1910.120(q), 1910.1200
OSHA Interpretation on Connected System 29 CF 1910.119(b) 1910.119(b)
Process Safety Management of Highly Hazardous Chemicals and Covered Concentrations of Listed Appendix A Chemicals 1910.119
Recognized and Generally Accepted Good Engineering Practices in Process Safety Management Enforcement 1910.119
RAGAGEP in Process Safety Management Enforcement 1910.119
Inspection Guidance for Poultry Slaughtering and Poultry Processing Establishments 1904 - Table of Contents, 1910 Subpart E, 1910.95, 1910.119, 1910.132, 1910.141, 1910.147, 1910.212, 1910.1200, 1913.10