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
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)
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)
Whether a combination course can meet refresher training requirements in 1910.120(e)(8) and the OSHA 10-hour construction industry outreach program. 1910.120, 1910.120(e)(8)
Whether the Demolition standard applies to moving a residential structure. 29 CFR 1926 Subpart T - Demolition. 1926.850, 1926.860, 1926 Subpart T
Chemical manufacturer's responsibility with regard to inorganic arsenic under OSHA's Hazard Communication Standard. 1910.1018, 1910.1018(a), 1910.1018(b), 1910.1018(p)(3), 1910.1200, 1910.1200(b)(2), 1910.1200(c)
Oil-filled transformers and underground construction. 1926.800(s)(3)
Whether an employee can waive right to have untested blood maintained for 90 days. 1910.1030, 1910.1030(f)(3)(iii)(B)
Whether to record two cases of employee injuries sustained in company parking lot during employees commute to work. 1904 - Table of Contents, 1904.5
Refresher training requirements for Class III asbestos work and training for excavations disturbing soil with ACM. 1926.1101, 1926.1101(b), 1926.1101(g), 1926.1101(k)(9), 1926.1101(k)(9)(ii), 1926.1101(k)(9)(v), 1926.1101(k)(9)(viii)
Storage and use of compressed gas cylinders; whether cylinder is considered an oxidizing compressed gas or oxygen cylinder. 1910.101, 1910.101(a), 1910.101(b), 1910.1200, 1910.1450
Employer selection of local fire department as its off-site rescue service for compliance with 29 CFR 1910.146(k)(1). 1910.146, 1910.146(k)(1)
Guarding and the use of abrasive wheels in CNC contouring machines. 1910.212, 1910.212(a), 1910.215, 1910.215(a), 1910.215(a)(1), 1910.215(a)(2), 1910.215(a)(2)(i)
Requirements for air receivers installed after August 27, 1971 and periodic retesting. 1910.169, 1910.169(a)(2)(i)
Clarification of the use and selection of BBP safety devices. 1910.1030, 1910.1030(b), 1910.1030(c)(1)(ii)(A), 1910.1030(c)(1)(ii)(B), 1910.1030(c)(1)(iv), 1910.1030(c)(1)(iv)(A), 1910.1030(c)(1)(iv)(B), 1910.1030(c)(2), 1910.1030(d)(2)(i)
Longitudinal spacing of egress steps in concrete drainage channels.
Employer payment for lineman belts and hooks when the equipment is used to comply with an OSHA standard. 1910.132, 1910.132(h)
Clarification of OSHA denial of FirePASS's variance request and respiratory protection requirements in oxygen-deficient atmospheres. 1910.134, 1910.134(d)(2)(iii)
Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER. 1910.120, 1910.120(e), 1910.120(e)(2)(i), 1910.120(e)(3)(i), 1910.120(q), 1910.120(q)(6)(iii), 1910.120(q)(6)(iii)(D)
Clarification of the requirement to provide accurate and current hazard information on an MSDS. 1910.1200, 1910.1200(g)(2)(xi)
Placement of sharps containers and requirement to ensure they are maintained in an upright position. 1910.1030, 1910.1030(c), 1910.1030(d)(4)(iii)(A)(2)(ii)