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 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
Manufacturer and distributor requirements for developing MSDS for hazardous products. 1910.1200, 1910.1200(d)
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)
MSDS requirement for occupational use of cosmetic Gentian Violet. 1910.1200, 1910.1200(b)(5)(iii), 1910.1200(b)(6)(viii), 1910.1200(b)(6)(ix)
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)
Use of generic MSDSs written by third-party companies and employer responsiblities when using an online MSDS service. 1910.1200, 1910.1200(g), 1910.1200(g)(2)
Responsibility of chemical manufacturers and importers to provide MSDSs to one or more establishments owned and managed by same employer. 1910.1200, 1910.1200(g)(6)(i)
PSM compliance for ammonia refrigeration systems. 1910.38, 1910.119, 1910.119(d)(3)(i), 1910.119(d)(3)(ii), 1910.119(e)(3), 1910.119(j)(6)(i), 1910.119(j)(6)(ii), 1910.119(k)(2), 1910.119(l)(2)(i), 1910.119(l)(4), 1910.119(l)(5), 1910.119(m)(3), 1910.119(o)(1), 1910.120, 1910.134, 1910.147, 1910.147(c)(4)(ii)
Operations that trigger the requirement for employers to provide washing facilities on construction jobsites under 29 CFR 1926.51(f)(1). 1926.51, 1926.51(f)(1), 1926.59, 1910.1200
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)
Training programs for the Control of Hazardous Energy (LOTO) and for the Hazard Communication standard are not satisfied solely by merely providing employees written documentation. 1910.147, 1910.147(c)(7)(i), 1910.1200, 1910.1200(h)
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
Requirements for maintaining Material Safety Data Sheets (MSDSs) for coal including coal dust, fly ash, and silica dust. 1910.1000 TABLE Z-1, 1910.1000 TABLE Z-3, 1910.1200, 1910.1200(d), 1910.1200(g)
Requirements for maintaining material safety data sheets (MSDSs) for consumer art products and office cleaning products. 1910.1200, 1910.1200(b)(6)(ix)
Requirement to disclose all chemicals having scientific evidence that they pose a health risk regardless of concentrations present in the product on the MSDS. 1910.1200, 1910.1200(g)(2)(i)(C)(2)