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
Emergency response training necessary for hospital physicians/nurses that may treat contaminated patients. 1910.120(q)(6), 1910.120(q)(8)
Reinforcing steel (rebar) assemblies: questions regarding fall protection and training. 1926.501(b)(5), 1926.502(d)(15), 1926.502(e)(2), 1926.503, 1926.701(b)
OSHA recordkeeping regulations are not subject to preemption under Section 4(b)(1) of the OSH Act. 1904 - Table of Contents
Clarification of apparent discrepancy in height requirements for stair and hand railings. 1910.23(e)(2), 1926.1052
Medical evaluation not required for the use of escape only respirators. 1910.134(e)
OSHA coverage does not extend to unpaid students. 1975.3
OSHA does not have jurisdiction over aircraft crews. 1975.1
Medical evaluations must be performed prior to fit testing. 1910.134(e)
Using X-ray fluorescence for analysis of lead in paint and applicability of other agencies lead levels. 1926.62, 1926.62(d), 1926.62(d)(2), 1926.62(d)(2)(i)(A)
OSHA's consultation program;assistance for smaller employers. 1908.5(b)
OSHA enforcement policy on vertical food mixers. 1910.263, 1910.212(a)(1), 1910.212(a)(3)(ii), 1910.147, 1910.147(a)(2)(ii)(A), 1910.147(a)(2)(ii)(B), 1910.147(a)(2)(iii)(A), 1910.305(g)
Accessibility of toilet facilities in temporary labor camps. 1910.142(d)(2)
U.S. Postal Service's equivalent to the OSHA 101 form.
Insulation issues: definition; plastic sheaths;and guarding requirements. 1926.416(a)
Applicability of 1910.146 to fall hazards into pits. 1910.146, 1910.146(b), 1910 Subpart D
CPR/first aid training and "working alone" provisions of 1910.269 1910.151, 1910.151(b), 1910.151(c), 1910.269, 1910.269(b)(1), 1910.269(l)(1)
Glass Capillary Tubes: Joint Safety Advisory About Potential Risks. 1910.1030
Clarification of systems for electronic access to MSDSs 1910.1200(g)
Anchoring of fall arrest system to aerial lifts; fall arrest vs. restraint systems. 1926.451(g), 1926.453(b)(2)(v), 1926.502(d)
Retention of medical records for companies ceasing to do business. 1910.1020(h)