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.

NOTICE:

How to Request a Letter of Interpretation

Filters


Date Title Standard Number
Clarification of the provision banning smoking in the OSHA asbestos standards. 1910.1001, 1910.1001(i)(4), 1915.1001(j)(4), 1926.1101, 1926.1101(j)(4)
OSHA's position on the use of Q104 needle removal device. 1910.1030, 1910.1030(d)(2)(viii)(A), 1910.1030(d)(2)(vii)(B)
OSHA's position on employer performing additional air monitoring that exceeds OSHA requirements. 1910.1000
Whether written programs may be kept solely in an electronic format. 1910.146(c)(4), 1910.1030(c)(1)(i), 1910.1030(c)(1)(iii), 1910.1200(e)(1), 1910.1200(e)(4)
Whether OSHA has jurisdiction to regulate the safety of professional baseball players and spectators.
Requirement for an employer to conduct an exposure assessment for tasks involving lead-containing paint 1926.62, 1926.62(d)(2), 1926.62(d)(2)(i)(A), 1926.62(d)(3)(iii), 1910.62(d)(3)(iv), 1926.62(d)(3)(iv)(A), 1926.62(d)(3)(iv)(B), 1926.62(n)(4)
OSHA's position on the use of lancets or lancing devices without safety-engineered features for finger prick blood sampling in the workplace. 1910.1030, 1910.1030(d)(2)(i)
Employee concern about overexposure to formaldehyde at FEMA trailer manufacturing sites. 1910.1048
Compliance of stair and platform railings with height requirements in OSHA standards for fixed industrial stairs. 1910.23, 1910.23(e)
Response to request for a meeting to discuss the Combustible Dust National Emphasis Program (NEP), CPL 03-00-006.
Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness. 1904 - Table of Contents, 1904.5, 1904.7, 1904.33
Requirement for annual BBP training for tattooing and body piercing artists and the use of written interpretations in the BBP training program. 1910.1030, 1910.1030(g)(2), 1910.1030(g)(2)(vii)
Requirements for labels and material safety data sheets for distributors of lumber. 1910.1200, 1910.1200(b)(6)(iv), 1910.1200(f)(2)(i), 1910.1200(g)(7)(iii)
Chemical manufacturer's responsibility with regard to inorganic arsenic under OSHA's Hazard Communication Standard. 1910.1018, 1910.1018(a), 1910.1018(b), 1910.1018(p)(3), 1910.1200, 1910.1200(b)(2), 1910.1200(c)
Whether a combination course can meet refresher training requirements in 1910.120(e)(8) and the OSHA 10-hour construction industry outreach program. 1910.120, 1910.120(e)(8)
Whether the Demolition standard applies to moving a residential structure. 29 CFR 1926 Subpart T - Demolition. 1926.850, 1926.860, 1926 Subpart T
Oil-filled transformers and underground construction. 1926.800(s)(3)
Whether an employee can waive right to have untested blood maintained for 90 days. 1910.1030, 1910.1030(f)(3)(iii)(B)
Whether to record two cases of employee injuries sustained in company parking lot during employees commute to work. 1904 - Table of Contents, 1904.5
Refresher training requirements for Class III asbestos work and training for excavations disturbing soil with ACM. 1926.1101, 1926.1101(b), 1926.1101(g), 1926.1101(k)(9), 1926.1101(k)(9)(ii), 1926.1101(k)(9)(v), 1926.1101(k)(9)(viii)