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
Evaluation of a box van of a truck carrying hazardous materials meeting the definition of a confined space in a hazardous material release/response situation. 1910.146, 1910.120(q)
MSDS's must be provided to employees who package/process drugs for distribution into final form if they contain hazardous chemicals 1910.1200, 1910.1200(b)(6), 1910.1200(b)(6)(vii), 1910.1200(e)
Responsibility of the employer and manufacturer to present consistent information between the labels and material safety data sheets. 1910.1200
Acceptability of using computer-based (on-line) training for the HAZWOPER 40-hour classroom training. 1910.120, 1910.120(e)
Hazard Communication: classification of uninterruptible power source batteries and office chemicals as "consumer products." 1910.1200, 1910.1200(c)
Requirements for manufacturers, who are no longer in business or have discontinued a product line, to provide MSDSs and product information. 1910.1200, 1910.1200(g)(1)
Application of OSHA standards to escape and protection of employees from threats associated with terrorist actions. 1910.120(q), 1910.38
Process operators' training requirements to take limited action in stopping an emergency release; role in an incident command system. 1910.120, 1910.120(q)(3)(i), 1910.120(q)(6)(ii), 1910.120(q)(6)(v)
Application of the hazard communication standard to latex paints containing less than 6% crystalline silica. 1910.1200
Material safety data sheet requirements for experimental chemical mixtures that are shipped off-site. 1910.1200, 1910.1200(b)(3)(iv), 1910.1200(g)
Application of HAZWOPER (1910.120) to terrorist and weapons of mass destruction incident responses. 1910.120, 1910.120(q)
OSHA-recognized chemicals as carcinogens or potential carcinogens for Hazard Communication purposes 1910.1200, 1910.1200(d)(4)(iii), 1910.1200(d)(5)(ii)
Current OSHA initiatives to improve quality of chemical hazard information provided to workers. 1910.1200, 1910.1200(g)
Firefighter training requirements to respond to emergency releases, or potential emergency releases, of hazardous substance. 1910.120, 1910.120(q)(6)(ii)
Requirements for emergency response and planning under the Process Safety Management Standard. 1910.38(a), 1910.38(c)(3), 1910.119(n), 1910.120(a), 1910.120(q), 1910.120(q)(1), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
Determination of airborne concentrations of methylene chloride; protection of employees covered by 1910.1052 1910.1052, 1910.1052(k), 1910.1200
HAZWOPER training requirements for hospital staff who decontaminate chemically contaminated patients. 1910.120
Employee and employee representative access to MSDS; accompanying CSHOs on inspections. 1910.1200, 1903 - Table of Contents, 1910.1200(g)(8), 1903.8, 1903.8(a), 1903.8(b), 1903.8(c), 1903.8(d)
Application of absorbent pads for spill control;hazardous waste site cleanup training does not qualify worker as hazardous materials technician. 1910.120, 1910.120(q)(6), 1910.120(e)
Respiratory protection and emergency escape requirements for IDLH atmospheres. 1910.120, 1910.120(q)(3), 1910.134, 1910.134(g)(3), 1910.146, 1910.146(i), 1910.146(k)(1)