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
Requirement to provide accessible quick drenching and flushing facilities where there is exposure to corrosive materials. 1910.151, 1910.151(c)
Evaluation of the ElectroGuard disconnect system for use as an energy isolating device. 1910.147, 1910.147(a)(2)(ii), 1910.147(b)
Assessing hazardous skin or eye exposure to hexavalent chromium for providing appropriate personal protective equipment. 1910.132, 1910.1026, 1910.1026(h)(1), 1915.152, 1915.1026, 1915.1026(g)(1), 1926.95, 1926.1126(g)(1)
Re: Application of OSHA's de minimis policy to the requirements of 29 CFR 1926.452(o)(3) and 29 CFR 1926.552(c)(1) - 1926.552(c)(4), 1926.552(c)(8), 1926.552(c)(13), 1926.552(c)(14)(i), and 1926.552(c)(16) regarding certain chimney construction work. 1926.20, 1926.20(b), 1926.32, 1926.32(f), 1926.32(m), 1926.104, 1926.451, 1926.451(a)(1), 1926.452, 1926.452(o)(3), 1926.502, 1926.502(d), 1926.552, 1926.552(a)(3), 1926.552(c)
Documentation of employees' hepatitis B vaccination status. 1910.1030(f)(2)(i), 1910.1030(f)(2)(ii), 1910.1030(h)(1)(ii)(B), 1910.1030(h)(1)(iv)
Whether to record injuries that occur to a contract employee when traveling from an offshore manned platform complex to other downfield fixed platforms. 1904 - Table of Contents, 1904.5, 1904.31
Clarification of several recordkeeping scenarios regarding the use of prescription medication in treating a work-related case. 1904 - Table of Contents, 1904.7
Whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms. 1904 - Table of Contents, 1904.5
Clarification on providing first aid training and maintenance of medical records under OSHA's BBP standard. 1910.151, 1910.151(b), 1910.1030, 1910.1030(h)(1)(ii)(A)
OSHA's requirement to provide first aid supplies specific to the needs of the workplace. 1910.151, 1910.151(b)
Whether urine containers and pregnancy tests need to be discarded in biohazard containers. 1910.1030(b)
Whether shielding is required when removing Becton Dickinson's blood tubes with a Hemoguard® closure. 1910.1030, 1910.1030(d)(2)(i), 1910.1030(d)(3)(x)
Detachable vs. permanent side shields for safety glasses; modifications to safety glasses. 1910.6, 1910.333, 1910.133(a)(2), 1910.133(b)(1), 1915.153, 1915.153(a)(2)
Re: Subpart L; scaffolds; Companion Rail, rail extensions for mobile scaffolds; 1926.451. 1926.451, 1926.451(a), 1926.451(g)(1), 1926.451(g)(4)(i), 1926.452, 1926.452(w)
Responsibility of chemical manufacturers and importers to provide MSDSs to one or more establishments owned and managed by same employer. 1910.1200, 1910.1200(g)(6)(i)
Wearing short-sleeved shirts while performing a thermal spray operation with exposure to hexavalent chromium fumes. 1910.132, 1910.1026(h)(1)
Acceptable time lapse for "annual" training. 1910.1030, 1910.1030(g)(2)(v)
Locked first aid cabinets in the workplace. 1910.151(b)
The use of safety-engineered devices and work practice controls in operating rooms; hospital responsibility to protect independent practitioners under BBP standard. 1910.1030, 1910.1030(c)(1)(iv)
Requirement for facility owners to notify tenants or employers of presence of ACM and PACM. 1910.1001, 1910.1001(j)(2)(iii), 1926.1101, 1926.1101(k)(2)(i), 1926.1101(k)(2)(ii)(D)