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 Standard Number
Numerous questions on lockout/tagout under 1910.147 and 1910.269 2 1910.269, 1910.147
OSHA's position on using a crawler crane that has been derated by the crane manufacturer. 6 1926.1417, 1926.1417(a), 1926.1417(c)(1), 1926.1401, 1926.1433, 1926.1433(d)(1)
Whether an employer's medical monitoring form meets the requirements under HAZWOPER. 2 1910.120, 1910.120(f)(7)
Applicability of OSHA's Cranes and Derricks standard to hoists attached to mast climbing platforms. 2 1926.1400, 1926.1400(a)
Whether apprenticeship programs qualify as third party qualified evaluators for purposes of evaluating signal person qualifications. 5 1926.1428, 1926.1428(a), 1926.1428(a)(3), 1926.1428(b), 1926.1430(b)
Rail Yard Tractors May Not Be Subject to the Powered Industrial Truck Standard 1 1910.178
Payment for ski helmets when used as PPE. 3 1910.132, 1910.132(a), 1910.132(h)
Requirement to name hazardous ingredients on MSDSs. 1 1910.1200
Enforcement of wheel chocking requirements in State Plan States. 2 1910.178, 1910.178(k)(1)
Determination of a manufactured product as an article under the Hazard Communication standard. 1 1910.1200
Shearing a structural member during demolition is not considered cutting as that term is used in 1926.62. 2 1926.62, 1926.62(d)(2)
Residential Contruction; 1926.501(b)(3), fall protection or metal stud walls around stairwells. 2 1926.501, 1926.501(b)(13)
Toprail height requirements for pump jack scaffolds. 4 1926.451, 1926.451(g)(4), 1926.452, 1926.452(j)
Clarification on whether an exercise regime is first aid or medical treatment 2 1904 - Table of Contents, 1904.7
Hand protection selection/usage while handling bacterial culture plates in a laboratory. 1 1910.1030
Providing the hepatitis B vaccine to companion-sitters who may provide first aid as a collateral duty. 3 1910.1030, 1910.1030(f)(2), 1910.1030(f)(1)(ii)(D)
Clarification of the Applicability of 29 CFR 1910.272(g) or (h) During Grain Storage Structure Entry Operations. 3 1910.272, 1910.272(g), 1910.272(h)
Clarification on when a worker may be inside a grain storage bin while a sweep auger is operating. 3 1910.272, 1910.272(g)(1)(ii), 1910.272(g)(6)
Applicability of the Hazard Communication standard to DEF tank operations. 4 1910.1200, 1910.1200(d)(3), 1910.1200(h)(3), 1910.1200(g)(8)
Clarification on when hard hats can be worn with bill facing to the rear. 2 1926.100, 1926.100(a)