Letters of Interpretation | Occupational Safety and Health Administration

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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Date	Title	Standard Number
11/29/1990	Training for 1910.120 to be specific to responder's needs.	1910.120, 1910.121
11/27/1990	Employee exposure to consumer products.	1910.1200
11/26/1990	Hazwoper does not require training for employees not involved or exposed to hazardous waste areas.	1910.120
11/19/1990	HCS applicability to hazardous by-products such as Ozone- generating operations	1910.1200(b)(1)
11/15/1990	"Laboratory setting" and subsequent requirements for Hazwoper.	1910.120, 1910.1200
11/14/1990	Definitions of Hazwoper terms including immediate, incidental & uncontrolled release.	1910.120
11/09/1990	First responders, training, hazardous materials technician, etc.	1910.120, 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
11/09/1990	Container labeling requirements under the OSHA Hazard Communication Standard	1910.1200(f)
11/09/1990	Communication Standard (HCS) to hydrotreated refined oils.	1910.1200
11/02/1990	Nuisance spills are not considered emergencies.	1910.120, 1910.1200
10/23/1990	Full time contract personnel at plant facility considered "workplace employees"	1910.120(q)(11)
10/18/1990	Hazard communication program on site and standard covering electrical installation, maintenance or repair.	1910.1200(e), 1910.331, 1910.332
10/15/1990	Hazard Communication Standard.	1910.1200
10/12/1990	Requirements for providing MSDS information for carcinogens which are a residue in a mixture	1910.1200(d)(5)
10/04/1990	Material Safety Data Sheets for methanol, windshield washer concentrate, and windshield washer solvent.	1910.1200
10/03/1990	Criteria to evaluate employee exposure in order to trigger the training requirements of 1910.120(e)	1910.120(a)(1), 1910.120(c), 1910.120(e), 1910.1200(e)
09/12/1990	Hazard Communication Standard, pertinent to distributors of hazardous chemicals.	1910.1200
09/05/1990	Training not required if employees not likely to be exposed to or participate in emergency response activities.	1910.120
08/22/1990	OSHA's Hazard Communication Standard.	1910.1200
08/09/1990	Training requirements for hazardous materials technicians and on- scene incident commanders.	1910.120(q)(6)