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

Filters


Date Title Standard Number Standard Number
Alleged deficiencies on an MSDS for one of Icynene's insulation products. 2 1910.1200(g), 1910.1200(g)(2)
Compliance with the OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030. 11 1910.1030, 1910.1030(a), 1910.1030(b), 1910.1030(c)(1), 1910.1030(c)(2), 1910.1030(d)(1), 1910.1030(d)(4)(iv), 1910.1030(d)(4)(iv)(A), 1910.1030(d)(4)(iv)(A)(1), 1910.1030(d)(4)(iv)(A)(3), 1910.1030(d)(4)(iv)(C)
Determining recordkeeping for work-relatedness of accident occurring during off-site event. 2 1904 - Table of Contents, 1904.5(b)(1)
Determining work-relatedness for recordkeeping of injury resulting from horseplay. 3 1904 - Table of Contents, 1904.4, 1904.5
Clarification on acceptability of National Environmental Trainers, Inc. (NET) interactive 40-hour training program. 1 1910.120
Permissibility of using electronic signature to satisfy the Annual Summary certification for OSHA Form 300-A. 2 1904 - Table of Contents, 1904.32
Alleged deficiencies contained on a material safety data sheet (MSDS) for a spray-on insulation product (the Icynene Insulation System). 3 1910.1200, 1910.1200(g)(1), 1910.1200(g)(2)
Whether a manufacturer-stipulated minimum anchor point elevation of 18 feet precludes the use of a shock absorbing lanyard in an aerial lift. 7 1926.453(a)(1)(v), 1926.453(b)(2)(v), 1926.500(a)(3)(i), 1926.500(b), 1926.502(d), 1926.502(d)(15), 1926.502(d)(16)(iii)
Requirements for personal protective equipment when removing asbestos-containing gaskets under OSHA's Asbestos standard for construction 1 1926.1101
Training requirements for fire investigators. 2 1910.120, 1910.120(q)(6)
Whether catch platforms (used to catch an employee in the event of a fall from a working surface above) must comply with OSHA's scaffold standard, Subpart L. 3 1926.450(b), 1926.451(a)(1), 1926 Subpart L
Requirements for labeling products that contain a nitrate or nitrite. 3 1910.1200, 1910.1200(b)(6)(ix), 1910.1200(f)(1)(i)
Requirements of the HCS and the employer's ability to rely on a manufacturer's hazard determination. 3 1910.132(d)(1), 1910.1200(g)(5), 1910.1200(h)
Whether employers have the option to establish new baseline audiograms when business ownership changes, but medical records are maintained for 30 years. 4 1910.95(g)(5), 1910.95(g)(9)(i), 1910.95(g)(9)(ii), 1910.95(m)(5)
OSHA's position on the use of Novartis' Fluvirin device. 4 1910.1030, 1910.1030(b), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i)
Re-qualification requirements for mobile crane operators engaged in construction work. 3 1926.20(b)(4), 1926.21(b)(2), 1926.550(b)(2)
OSHA's position on the use of fingers or a two-handed procedure with a hemostat to remove scalpel blades. 3 1910.1030, 1910.1030(d)(2)(vii)(A), 1910.1030(d)(2)(vii)(B)
Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters. 3 1910.120(q)(6)(i), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
Contractor responsibilities for health and safety when removing asbestos-containing materials from private dwellings. 1 1926.1101
Extent of OSHA's jurisdiction over worksites involving geological and underground storage facilities for gas and hazardous liquids. 3 1910.119, 1910.119(a)(2)(ii), 1910.119(b)