Letters of Interpretation | Occupational Safety and Health Administration

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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How to Request a Letter of Interpretation

Date	Title	Standard Number
10/22/2001	Clarification of minimum face velocity requirements for spray booths	1910.107(b)(5), 1910.94(c)(6)(i), 1910.1000
10/17/2001	OSHA has no authority over merchant/customer relationships.	1975.3
10/17/2001	Acceptable methods to reduce heat stress hazards in the workplace.
09/27/2001	History and background of the Steel Erection Final Rule.	1926.750, 1926.751, 1926.752, 1926.753, 1926.754, 1926.755, 1926.756, 1926.757, 1926.758, 1926.759, 1926.760, 1926.761
09/26/2001	Differentiation between the 80 dBA threshold for hearing conservation and the 90 dBA PEL.	1910.95
09/26/2001	Application of Asbestos Standards to repair and maintenance operations.	1926.1101, 1910.1001, 1910.12(b)
09/25/2001	Applicable standards to protect employees, not engaged in electrical work, operating an aerial lift within 10 feet of overhead electrical lines.	1926.400, 1926.400(b), 1926.402, 1926.408, 1926.416(a)(1), 1926.416, 1926.417, 1926.431, 1926.432, 1926.441, 1926.449, 1926.453(a)
09/21/2001	Requirements of using cranes to hoist personnel.	1926.550, 1926.550(a), 1926.550(a)(1), 1926.550(g)
09/21/2001	Clarification of utility "owner" as used in the Safety and Health Standards for Excavations, Underground Installations.	1926.651(b)(2), 1926.651(b), 1926.650, 1926.651, 1926.652
09/18/2001	Fall protection requirements of various construction (1926) standards.	1926.502, 1926.751, 1926.752(d), 1926.753(c)(1)(i), 1926.753(c)(2), 1926.753(d), 1926.757(a)(9), 1926.759(b), 1926.760(a)(2), 1926.760(b)(3), 1926.760(c), 1926.760(c)(3), 1926.760(d)(3), 1926.760(e)
09/17/2001	Full compliance with NFPA 33-2000 may be considered a de minimus violation.	1910.107(d)(9)
09/13/2001	Fall protection requirements for both residential and commercial HVAC systems; clarification of confined spaces	1926.501(b), 1926.501(b)(1), 1926.502(f)(2), 1910.132(a), 1926.21(b)(6), 1926.21(b)(6)(ii), 1910.146
09/10/2001	Plasma derivatives are covered by the Bloodborne Pathogens Standard.	1910.1030, 1910.1030(b)
08/30/2001	Above-ground 500-gallon polyethylene tank is unacceptable for storage of flammable and combustible liquids	1910.106(b)(1)(i), 1910.106(a)(18)(ii)(b)
08/27/2001	Two employees must be present during work on energized systems >600 volts	1910.269(l)(1)(i), 1910.269(l)(1)(ii)
08/27/2001	Determining if a state hospital is an employer under the OSHAct.	1975.5(b), 1975.5(c)
08/27/2001	Compliance with NFPA 30-2000 ventilation requirements is considered a deminimus violation	1910.106(e)(3)(v)(a)
08/24/2001	Standard syringes may still be used in certain situations.	1910.1030(d)(2)
08/17/2001	Evaluation of safer medical devices and the use of therapeutic radiopharmaceuticals.	1910.1030
08/16/2001	Clarification of residential construction and fall protection requirements.	1926 - Table of Contents, 1926.500, 1926.501, 1926.502, 1926.503