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

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Date Title Standard Number
Applicability of the HCS to office workers and copy machine operators. 1910.1200
Asserting jurisdiction under State law over any occupational safety or health issue with respect to which no standard is in effect. 1903.20, 1910.141
Revised Hazard Communication Standard (HCS) Instruction, CPL 2-2. 38B CH-1 1910.1200
Application of the HCS to certain products containing crystalline silica. 1910.1200(b)(2)
Interpretation of 1910.106(d)(2)(i), as it applies to the storage of combustible liquids in polyethylene containers. 1910.106(d)(2)(i)
The use of the "Billy Pugh" type basket. 1926.550(g)(4), 1926.550(g)(4)(i)(b), 1926.550(g)(4)(ii)(a), 1926.550(g)(4)(ii)(b), 1926.550(g)(4)(ii)(e), 1926.550(g)(4)(ii)(f), 1926.550(g)(4)(ii)(f), 1926.550(g)(4)(ii)(I), 1926.550(g)(4)(iv)(a)
Distributor's and retailer's responsibilities for providing MSDSs. 1910.1200(g)
Medical exams required under the asbestos standards. 1910.1001(l), 1926.1101(m)
Respiratory Protection for Mercury and Chlorine 1910.134
When and how it it permissible for employees to be hoisted on the load lines of cranes and derricks. 1926.550(g)
Formaldehyde Standard Clarification 1910.1048(h)(1)(ii)
Request for a regulatory clarification concerning commercial carbon black. 1910.1000
Metal cyclones Supplied by SKC Inc. are not to be used for sampling respirable dust. 1910.1000
Listing of decomposition products on MSDSs where they are present during normal use or only in the event of a fire. 1910.1200(g)
Labelling requirements for chemicals transported to another plant of the same company under the HCS. 1910.1200(f)
Distributor of health care products would be a "distributor" rather than a "retail distributor" under the HCS. 1910.1200(g)
The ENCON/FT-Collection meets the intent of the OSHA eye and face protection standard. 1910.133(b)(2)
Rubber protective equipment shall be in accordance with the provisions of (ANSI). 1926.951
Survey questionnaire concerning the use of computers by inspectors during enforcement.
Applicability of the HCS to crystalline silica, when bound in a polymeric compound and silicone rubber elastomers. 1910.1200