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
Qualifications required under 1910.269 for entry into manholes/vaults to perform work on energized conductors. 1910.146, 1910.269, 1910.269(a)(2), 1910.269(a)(2)(ii), 1910.269(e)(2), 1910.269(l)(1), 1910.269(l)(2), 1910.269(t)
Requirements for developing entry procedures for permit-required confined spaces. 1910.146, 1910.146(c)(2), 1910.146(c)(3), 1910.146(c)(8), 1910.146(d)(3)
Construction of aboveground storage tanks and confined space; §§1926.21(b)(6) and 1910.146; General duty clause 1926.21, 1926.21(b)(6), 1926.21(b)(6)(i), 1926.21(b)(6)(ii), 1910.146, 1910.146(c)(5)
Clarification of "potential atmospheric hazard" when reclassifying a PRCS as a non-permit required confined space. 1910.146(b), 1910.146(c)(7), 1910.146(c)(7)(i)
Clarification of "continuous forced air ventilation" for PRCS entry work. 1910.146(c)(5)(i), 1910.146(c)(5)(ii)(E)
CPR training is a required element in some OSHA general industry standards. 1910.151(b), 1910.146, 1910.266, 1910.269
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)
Questions regarding the Permit-Required Confined Space standard, 1910.146, and the Grain Handling standard, 1910.272. 1910.146, 1910.146(c)(2), 1910.272, 1910.272(e)(1)(i), 1910.272(g), 1910.272(g)(3), 1910.272(g)(5)
Automated External Defibrillator training is not specifically required by the Permit-Required Confined Space standard; AEDs are not required first aid supplies. 1910.146(k)(2)(iii), 1910.151(b)
Clarification of maintenance vs. construction activities; standards applicable to the removal and replacement of steel tanks and structural steel supports. 1926.32(g), 1910.12(a), 1910.12(b), 1926.750(b)(1), 1926.750(b)(2), 1926.750(a), 1926.105, 1910.146
Response to Edison Electric Institute's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard." 1910.269, 1910.269(d), 1910.269(d)(8)(v), 1910.146, 1910.147
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)
Applicability of the confined-space standard to dock-leveler pits. 1910.146, 1910.146(b), 1910.146(c)(7), 1910.146(c)(7)(i), 1910.146(c)(7)(ii), 1910.146(c)(7)(iii), 1910.146(c)(7)(iv), 1910.147
Fall protection requirements for both residential and commercial HVAC systems; clarification of confined spaces 1926.501(b), 1926.501(b)(1), 1926.502(f)(2), 1910.132(a), 1926.21(b)(6), 1926.21(b)(6)(ii), 1910.146
Application of the Confined Spaces Advisor to construction; personal fall arrest system requirements. 1926.21(b)(6)(i), 1926.353(b), 1926.502(d), 1926.651(g), 1926.800, 1926.956, 1910.146(a)
An attendant may participate in non-entry confined space rescue under certain conditions. 1910.146(k), 1910.146(i)
OSHA policies concerning employees working at home. 1904.14, 1910.1200(g), 1910.147, 1910.146, 1910.132
Confined space requirements for a testing chamber with/without limited access. 1910.146(c), 1910.146(c)(5)
OSHA policies concerning employees working at home. 1904.14, 1910.1200(g), 1910.147, 1910.146, 1910.132
PRCS entry: the term "body" includes all extremities. 1910.146(b)