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
The predominant use of structural steel would not be considered "residential construction" 1926.501(b)(13), 1926.502(k)
Portable ladders not extending 3 feet above upper landing must be secured. 1926.1053, 1926.1053(b)(1)
Identification, inspection, and marking of cranes when manufacturer-supplied identifications are unavailable. 1926.550, 1926.550(a), 1926.550(a)(5), 1926.550(a)(6), 1926.550(b)(2), 1926.550(c), 1926.550(d), 1926.550(e), 1926.550(f), 1926.32(f)
Permissibility of attaching welding leads to an occupied aerial lift bucket and using an external lifeline to anchor fall arrest equipment. 1926.351(c)(6), 1926.453(b)(2)(xi), 1926.453(b)(2)(v), 1926.453(b)(2)(iii), 1926.453(b)(2)(vi)
Hard hats are not required where there is no exposure to head injuries. 1926.100, 1926.100(a)
Fall protection components from different manufacturers may be used together provided connecting parts are sized compatibly. 1926.502, 1926.502(d), 1926.502(d)(5), 1926.502(d)(6), 1926.502(e)(7), 1926.502(e)(8)
Inspection, testing, and operation requirements for Woltman PVE 5021S pile driving equipment. 1926.20, 1926.20(b)(2), 1926.31, 1926.550, 1926.550(a), 1926.550(a)(17), 1926.550(b), 1926.550(b)(2)
Process operators' training requirements to take limited action in stopping an emergency release; role in an incident command system. 1910.120, 1910.120(q)(3)(i), 1910.120(q)(6)(ii), 1910.120(q)(6)(v)
Employees with occasional exposure to noise levels in excess of 85 dBA TWA must be included in the company's hearing conservation program. 1910.95
Minimum toe clearance for workers using manhole rungs during construction work. 1926.27(c)(4), 1926.1053(a)(13)
Minimum exposure for inclusion in the hearing conservation program (HCP); removal criteria. 1910.95, 1910.95(c)(1), 1910.95(m)
Application of the hazard communication standard to latex paints containing less than 6% crystalline silica. 1910.1200
Use of laser guarding systems with hydraulic press brakes 1910.212, 1910.212(a)(1), 1910.212(a)(3)
Clarification of "authorized" and "affected" employees and proper energy control procedures. 1910.147(b), 1910.147(c)(4), 1910.147(c)(7)(i), 1910.147(d), 1910.147(d)(4)(i), 1910.147(f)(3)(ii), 1910.147(f)(3)
Current studies on the use of engineering controls to decrease asbestos exposures to mechanics performing brake and clutch repair. 1910.1001, 1910.1001(j)(4), 1910.1001(f)(3)
Requirements for load-testing and marking of special custom-design rigging accessories; applicability of ASME standards. 1926.251, 1926.251(a)(4), 1926.32, 1926.32(q)
Fall protection requirements for work docks/bridges used during bridge construction. 1915.2, 1910.12(a), 1917.1(a), 1926.450(b), 1926.451(g)(1), 1926.106
Fit testing requirements for employees who wear respirators to protect against M. Tuberculosis, SARS, Smallpox, and Monkeypox. 1910.134, 1910.134(f)
Material safety data sheet requirements for experimental chemical mixtures that are shipped off-site. 1910.1200, 1910.1200(b)(3)(iv), 1910.1200(g)
Requirements for providing seatbelts for drivers whose size precludes their using seatbelts. 1926.601, 1926.601(b)(9), 1926.95(a), 1910.132(a), 1926.601(a)