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
Clarification of "trade secret" and the employer's obligation to provide genetic coding information. 1910.1020, 1910.1020(c)(5), 1910.1020(c)(6), 1910.1020(c)(13), 1910.1020(c)(14), 1910.10(e)(1)(iii), 1910.1020(e)(1)(iv), 1910.1020(f)(4), 1910.1020(f)(4)(ii), 1910.1020(f)(4)(iv)
Worker exposure to impalement hazards while constructing upper rebar mats over rebar protrusions from lower levels 1926.701, 1926.701(b)(1)
The use of rail extensions on ladders used in a general industry setting. 1910.25, 1910.26
Whether the four-bolt requirement in 1926.755(a)(1) applies to a pre-existing column that will be left in place during a renovation/alteration project. 1926.755, 1926.755(a)(1)
Impalement from reinforcing steel protruding horizontally; §1926.701(b) 1926.701(b)
Training requirements for powder-actuated tools under §1926.302(e). 1926.21(b)(2), 1926.32(f), 1926.302(e), 1926.302(e)(1)
Whether the notification required in §1926.752(a)(1) (attained concrete strength) must be given where steel will be erected on a long-existed concrete slab. 1926.752, 1926.752(a), 1926.752(a)(1)
Requirement for flame-resistant clothing in petrochemical plant covered by PSM. 1910.132, 1910.132(a), 1910.119, 1910.119(f)(1)(iii)(B), 1910.119(h)(2), 1910.119(h)(3), 1910.119(j)(2)
Fall protection and aerial lifts in the Electric Power Generation, Transmission, and Distribution industries. 1910.28, 1910.28(a)(12), 1910.28(d)(7), 1910.28(d)(12), 1910.29, 1910.29(a)(3), 1910.67, 1910.269, 1910.269(a)(2)
Access to toilet facilities in a call center. 1910.141, 1910.141(c)(1)(i)
Tuberculosis and Respiratory Protection: prohibition on enforcement of annual fit testing requirements during fiscal year 2006. 1910.134, 1910.134(f)(2), 1910.134(f)(3)
Policy on powered industrial truck operators using prescribed drugs. 1910.178
Alternative fall protection program when guardrails are infeasible to install. 1910.23, 1910.23(c)
Employer's duty to inform auto mechanic of presence of blood in vehicle being repaired. 1910.1030, 1910.1030(b)
Use of cages, wells, and personal fall protection systems to protect against falls from fixed ladders. 1910.27
The use of ship's stairs instead of fixed stairs in general industry. 1910.27
Clarification on revising a baseline audiogram if a standard threshold shift occurs in only one ear. 1910.95, 1910.95(g)(9)
Circumstances under which installation of fixed industrial stairs with a slope between 50 degrees and 70 degrees from the horizontal would be considered a de minimis violation. 1910.24
Facial hair and voluntary use of filtering facepiece respirators. 1910.134, 1910.134(a), 1910.134(c)(2)(ii)
Applicability of the Fire brigade standard to health care facilities. 1910.156, 1910.156(a)