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
Immunizations or inoculations (except tetanus) are recordable when given in response to a workplace injury or illness. 1904 - Table of Contents, 1904.7(b)(5)(ii)(B)
Participation by professional sports teams in the Bureau of Labor Statistics Survey of Occupational Injuries and Illnesses; definition of independent contractor versus employee. 1904 - Table of Contents, 1904.31
Recording criteria for cases involving workers from a temporary help service, employee leasing service, or personnel supply service. 1904 - Table of Contents, 1904.29, 1904.31, 1904.33, 1904.35, 1904.40, 1904.46
Response to Edison Electric Institute's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard." 1910.269, 1910.269(d), 1910.269(d)(8)(v), 1910.146, 1910.147
Response to Exelon Generation's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard." 1910.269, 1910.269(d), 1910.269(d)(8)(v), 1910.147
Clarification on the USPS's lockout/tagout procedures and minor servicing operations for the multiple line optical character recognition sorter. 1910.147, 1910.147(a)(2)(ii)
Storage of materials that prevents inspection of scaffolds before workshifts; incidental storage amounts that do not inhibit scaffold inspection. 1926.250, 1926.250(b)(5), 1926.451, 1926.451(b)(9), 1926.451(f)(3)
Employer's responsibility to protect employees from workplace hazards through appropriate hazard control methods 1910.106, 1910.106(b)(6), 1910.1000
Potential exposure to contaminated sharps in the solid waste industry. 1910.1030, 1910.1030(c)(2)(i)
OSHA does not specify payment requirements for apparel covered in the Electrical Power Transmission and Distribution Standard. 1910.269, 1910.269(l)(6)(iii)
Electrical conductors and equipment must be approved and used according to its listing/label. 1910.303, 1910.303(a), 1910.303(b)(2)
Employer must shore or otherwise protect employees who walk/work at the base of an embankment from a possible collapse.
Fall protection requirements for an employee working from a ladder on a walking/working surface other than the ground. 1926.500, 1926.500(a)(2)(vii), 1926.500(b), 1926.501, 1926.501(b)(1), 1926.1050, 1926.1052, 1926.1053, 1926.1060
Written notification of ASTM strength test for mortar in masonry piers/walls prior to steel erection. 1926.752, 1926.752(a), 1926.752(a)(1), 1926.752(b)
Repair requirements for the cord plug (attachment plug) of double-insulated tools. 1926.302, 1926.302(a), 1926.302(a)(1), 1926.403, 1926.403(a), 1926.404, 1926.404(b)(1)(iii)(C), 1926.404(f)(7)(iv), 1926.404(f)(3), 1926.404(f)(7), 1926.405(g)(2)(iii), 1926.449
OSHA machine guarding standards and the ISO/IEC standards adopted under the GATT; National Emphasis Program on Amputations 1910.211, 1910.212, 1910.213, 1910.214, 1910.215, 1910.216, 1910.217, 1910.218, 1910.219
Acceptability of modifying a standard on/off switch to provide lockout capability to a machine. 1910.147, 1910.147(c)(3), 1910.147(c)(2)(iii), 1910.303(a), 1910.399, 1910.303
Electrical safety requirements for rechargeable racks for paging transmitters. 1910.305(j)(3), 1910.399
Determination of airborne concentrations of methylene chloride; protection of employees covered by 1910.1052 1910.1052, 1910.1052(k), 1910.1200
Baseline audiogram revision due to persistent STS or improved thresholds; revision must be made for each ear separately. 1910.95, 1910.95(g)(1), 1910.95(g)(5), 1910.95(g)(7), 1910.95(g)(9), 1910.95(g)(10), 1904 - Table of Contents, 1904.10