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
Using a stepladder as a non-self-supporting ladder. 3 1926.1053, 1926.1053(a)(2), 1926.1053(b)(4)
Bloodborne Pathogens Standard, OSHA's Personal Protective Equipment Standard 1 1910.132
OSHA requirement for sharps containers to be closable 1 1910.1030(d)(4)(iii)(A)(l)(i)
Exposure to radon when working in trenches or excavations. 3 1910.1096, 1910.1096(c)(1), 1926.53
Medical exams and blood testing for zinc protoporphyrin (ZPP) under OSHA's Lead Standards. 2 1910.1025, 1910.1025(j)(1)(i)
Consuming food and/or beverages in the same work area where known hazardous chemicals are used. 3 1910.141, 1910.141(a)(2), 1910.141(g)(2)
Compliance with 1926.1101 when drilling through asbestos-containing floor tile/mastic. 4 1926.1101, 1926.1101(g), 1926.1101(g)(5), 1926.1101(g)(9)
Whether manual joint manipulation is considered first aid or medical treatment for recordkeeping purposes 2 1904 - Table of Contents, 1904.7
Clarification on equivalent test nebulizer for qualitative fit tests. 1 1910.134
Confidentiality of employee post-exposure evaluations as it pertains to the Bloodborne Pathogens Standard; use of portable fans in phlebotomy collection rooms. 4 1910.1030, 1910.1030(f)(3), 1910.303, 1910.303(b)(2)
OSHA's position on mandatory flu shots for employees. 0
Painting or placement of adhesive stickers on protective helmet shell. 3 1910.132, 1910.132(a), 1910.135
The use of clevis pins and cotterpins to attach slings and hooks; use of latches on sling hooks. 3 1910.184(e)(2)(i), 1910.184(e)(2)(ii), 1910.184(f)(6)
Whether compliance with an updated ANSI standard on gate strength for carabiners and snaphooks is required. 2 1926.502, 1926.502(d)
Protective system requirements for excavations that will not be entered by employees. 4 1926.652, 1926.652(a)(1), 1926.652(b), 1926.652(c)
Hazards associated with aluminum grinding. 2 1915.4(r), 1915.504(b)
Using the Globally Harmonized System (GHS) to Comply with OSHA's Hazard Communication Standard. 2 1910.1200, 1910.1200(f)
Clarification on prescription medications and recordkeeping requirements 2 1904 - Table of Contents, 1904.7(b)(5)(ii)(A)
Clarification of preexisting injury/illness and recordkeeping 2 1904 - Table of Contents, 1904.5
Guarding of Access Openings to Fixed Ladders. 3 1910.23, 1910.23(a)(2), 1910.27