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

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Date Title Standard Number
Interpretation concerning 1910.120 requirements for air monitoring, a site safety and health plan, training, and medical surveillance 1910.120, 1910.120(h), 1910.120(b)(1)(v), 1910.120(c)(7), 1910.120(b)(1)(iv), 1910.120(e)(1), 1910.120(e)(3), 1910.1020
Exemption of hazardous waste samples sent to a laboratory for analysis from the Hazard Communication Standard. 1910.1200
Enforcement of the Hazard Communication Standard 1910.1200
Copies of MSDSs and the written hazard communication program must be provided to an employee representative. 1910.1200
Qualifications for instructors under the training requirements of OSHA's Hazardous Waste and Emergency Response interim final rule. 1910.120
Training requirements under 1910.120 for employees providing services which do not disturb the hazardous materials on a waste site. 1910.120(e)
Overwarning on Hazard Labels 1910.1200(f)
Use of direct reading instruments to comply with the monitoring requirements in the Hazardous Waste Operation and Emergency Response interim final rule. 1910.120
HCS training for employees contracted to jobs working under the supervision of another employer. 1910.1200(h)
Letter to Lawrence N. Curcio from Thomas Shepich concerning requirements of the HCS on labeling of IARC category 2B carcinogens 1910.1200
Clarification of Material Safety Data Sheet Requirements Under the Hazard Communication Standard. 1910.1200
Office workers routinely performing short clean up procedures using chemicals covered by the HCS. 1910.1200
Material Safety Data Sheet Requirements Under the Hazard Communication Standard. 1910.1200(g)
Employers are responsible for training new employees on the HCS 1910.1200(h)
Articles such as styrofoam and white-out exempt from HCS requirements in florist shops. 1910.1200(b)(6)(iv)
Retraining employees who have been previously trained by another employer. 1910.1200(h)
Material safety data sheets for liquid plant food. 1910.1200(g)
Applicability of the HCS to alpha-alumina 1910.1200(d)
Definition of "distributor" and "retail distributor" as used in paragraph 29 CFR 1910.1200(g)(7). 1910.1200(g)(7)
The employer must provide the 1910.1200 verbal training in a language that is comprehensible. 1910.1200(h)