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
Oil-filled transformers and underground construction. 1 1926.800(s)(3)
Whether an employee can waive right to have untested blood maintained for 90 days. 2 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. 2 1904 - Table of Contents, 1904.5
Refresher training requirements for Class III asbestos work and training for excavations disturbing soil with ACM. 7 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)
Employer selection of local fire department as its off-site rescue service for compliance with 29 CFR 1910.146(k)(1). 2 1910.146, 1910.146(k)(1)
Storage and use of compressed gas cylinders; whether cylinder is considered an oxidizing compressed gas or oxygen cylinder. 5 1910.101, 1910.101(a), 1910.101(b), 1910.1200, 1910.1450
Guarding and the use of abrasive wheels in CNC contouring machines. 7 1910.212, 1910.212(a), 1910.215, 1910.215(a), 1910.215(a)(1), 1910.215(a)(2), 1910.215(a)(2)(i)
Requirements for air receivers installed after August 27, 1971 and periodic retesting. 2 1910.169, 1910.169(a)(2)(i)
Longitudinal spacing of egress steps in concrete drainage channels. 0
Clarification of the use and selection of BBP safety devices. 9 1910.1030, 1910.1030(b), 1910.1030(c)(1)(ii)(A), 1910.1030(c)(1)(ii)(B), 1910.1030(c)(1)(iv), 1910.1030(c)(1)(iv)(A), 1910.1030(c)(1)(iv)(B), 1910.1030(c)(2), 1910.1030(d)(2)(i)
Clarification of OSHA denial of FirePASS's variance request and respiratory protection requirements in oxygen-deficient atmospheres. 2 1910.134, 1910.134(d)(2)(iii)
Employer payment for lineman belts and hooks when the equipment is used to comply with an OSHA standard. 2 1910.132, 1910.132(h)
Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER. 7 1910.120, 1910.120(e), 1910.120(e)(2)(i), 1910.120(e)(3)(i), 1910.120(q), 1910.120(q)(6)(iii), 1910.120(q)(6)(iii)(D)
Placement of sharps containers and requirement to ensure they are maintained in an upright position. 3 1910.1030, 1910.1030(c), 1910.1030(d)(4)(iii)(A)(2)(ii)
Clarification of the requirement to provide accurate and current hazard information on an MSDS. 2 1910.1200, 1910.1200(g)(2)(xi)
Request to provide list of corrosive materials and concentrations requiring use of emergency eyewashes and showers. 6 1910.132(d), 1910.133(a)(1), 1910.151(c)(1), 1910.1200(c), 1910.1200(g), 1926.50(g)
Use of jack stands in the stabilization of semi-trailers. 2 1910.178, 1910.178(k)(3)
Whether a pH buffer solution can be used as a cleansing agent for employees who work with portland cement 7 1910.141(d)(2), 1910.141(d)(2)(i), 1910.141(d)(2)(ii), 1910.141(d)(2)(iii), 1910.141(d)(2)(iv), 1915.97(b), 1926.51(f)(1)
Requirements for spray booth when spraying water-based paint. 5 1910.94, 1910.94(c), 1910.94(c)(2), 1910.94(c)(8), 1910.107
Clarification of employer's obligation to include social security numbers on employee exposure records. 5 1910.1025, 1910.1025(d)(5), 1910.1025(n)(1)(i), 1910.1025(n)(1)(ii)(D), 1910.1026