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 Standard Number
Restrictions on drilling within 50 feet of a hole loaded with explosives. 4 1926.905, 1926.905(h), 1926.905(j), 1926.905(k)
Whether guardrails are required on a two-point adjustable scaffold while workers who are tied off are painting the undercarriage of a water storage tank. 4 1926.451, 1926.451(b)(2)(ii), 1926.451(b)(3), 1926.451(g)(1)(ii)
Permissible methods of operating trucks in reverse on construction sites. 3 1926.601, 1926.601(b)(4), 1926.602(a)(9)(ii)
Storing Lunches in a Refrigerator at an Auto Collision Shop 1 1910.141
Fully Planked and Decked Scaffold 2 1926.451, 1926.451(b)(1)
Fall protection requirements for employees working on an elevator car frame. 4 1926.500(b), 1926.501(b)(1), 1926.502(d), 1926.502(d)(15)
Interpretation of OSHA Fall Protection Exemption (29 CFR 1926.500(a)(1)) during inspection, investigation, and assessment activities. 2 1926.500, 1926.500(a)(1)
Whether an employer can use a controlled access zone during curtain wall installation. 7 1926.500, 1926.500(a)(2)(iii), 1926.502, 1926.502(g), 1926.751, 1926.760, 1926.760(a)(1)
Testing requirements for "lifting blinds" or "lifting covers" on pressure vessels. 3 1926.251, 1926.251(a)(4), 1926.251(a)(5)
Clarification on whether the HAZWOPER standard applies to Weapons of Mass Destruction Civil Support Teams responding to a terrorist incident. 1 1910.120
Hazards of using a crane's hydraulic system to compensate for inadequate brakes. 4 1926.1433, 1926.1433(b)(5), 1926.1434, 1926.1434(a)(3)
Trainer qualifications under the HAZWOPER standard. 1 1910.120
Clarification of assigned working hours when recording work-related injuires/illnesses. 2 1904 - Table of Contents, 1904.5
Clarification of OSHA's position on preemption precluding state court findings with regard to defective NIOSH-certified respirators. 1 1910.134
Clarification on number of qualified employees required when working with electrical components. 3 1910.269, 1910.269(l)(1), 1910.269(l)(2)
Use of gloves by masons 2 1926.95, 1926.95(a)
"Applicability of the PSM standard's mechanical intergrity requirements to refinery structures." 5 1910.119, 1910.119(d)(3), 1910.119(e), 1910.119(j), 1910.119(l)
Definition of a single use and negative pressure respirator 1 1910.134
OSHA requirements for mercury response and clean-up personnel in a number of different site-specific scenarios. 2 1910.120, 1910.1000
Clarification of the term abnormal condition as used in the Recordkeeping standard 3 1904 - Table of Contents, 1904.4(a), 1904.46