Letters of Interpretation | Occupational Safety and Health Administration

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

Date	Title	Standard Number
11/07/2008	Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters.	1910.120(q)(6)(i), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
10/16/2008	Contractor responsibilities for health and safety when removing asbestos-containing materials from private dwellings.	1926.1101
10/07/2008	Extent of OSHA's jurisdiction over worksites involving geological and underground storage facilities for gas and hazardous liquids.	1910.119, 1910.119(a)(2)(ii), 1910.119(b)
10/02/2008	Determining scaffold support capability.	1910.28, 1910.28(a)(2), 1910.28(a)(4)
09/29/2008	Clarification of OSHA regulation 29 CFR 1910.159(c)(10), Sprinkler spacing.	1910.159(c)(10)
09/29/2008	Grain handlers and engulfment hazards; procedures for unguarded sweep augers.	1910.23(a)(5), 1910.272, 1910.272(e)(2), 1910.272(g)(1)(ii), 1910.272(g)(2)
09/26/2008	Riggs – PSM Coverage of Biodiesel Facilities	1910.119(a)(1)(ii)(B)
09/25/2008	Clarification of the provision banning smoking in the OSHA asbestos standards.	1910.1001, 1910.1001(i)(4), 1915.1001(j)(4), 1926.1101, 1926.1101(j)(4)
09/25/2008	OSHA's position on the use of Q104 needle removal device.	1910.1030, 1910.1030(d)(2)(viii)(A), 1910.1030(d)(2)(vii)(B)
09/16/2008	Whether written programs may be kept solely in an electronic format.	1910.146(c)(4), 1910.1030(c)(1)(i), 1910.1030(c)(1)(iii), 1910.1200(e)(1), 1910.1200(e)(4)
09/16/2008	OSHA's position on employer performing additional air monitoring that exceeds OSHA requirements.	1910.1000
09/12/2008	Whether OSHA has jurisdiction to regulate the safety of professional baseball players and spectators.
09/10/2008	Requirement for an employer to conduct an exposure assessment for tasks involving lead-containing paint	1926.62, 1926.62(d)(2), 1926.62(d)(2)(i)(A), 1926.62(d)(3)(iii), 1910.62(d)(3)(iv), 1926.62(d)(3)(iv)(A), 1926.62(d)(3)(iv)(B), 1926.62(n)(4)
09/09/2008	Employee concern about overexposure to formaldehyde at FEMA trailer manufacturing sites.	1910.1048
09/09/2008	OSHA's position on the use of lancets or lancing devices without safety-engineered features for finger prick blood sampling in the workplace.	1910.1030, 1910.1030(d)(2)(i)
08/27/2008	Compliance of stair and platform railings with height requirements in OSHA standards for fixed industrial stairs.	1910.23, 1910.23(e)
08/26/2008	Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness.	1904 - Table of Contents, 1904.5, 1904.7, 1904.33
08/26/2008	Response to request for a meeting to discuss the Combustible Dust National Emphasis Program (NEP), CPL 03-00-006.
07/31/2008	Requirements for labels and material safety data sheets for distributors of lumber.	1910.1200, 1910.1200(b)(6)(iv), 1910.1200(f)(2)(i), 1910.1200(g)(7)(iii)
07/31/2008	Requirement for annual BBP training for tattooing and body piercing artists and the use of written interpretations in the BBP training program.	1910.1030, 1910.1030(g)(2), 1910.1030(g)(2)(vii)