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

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Date Title Standard Number
Clarification of whether an employee can opt out of medical surveillance examinations under the HAZWOPER standard, 29 CFR 1910.120. 1910.120, 1910.120(f), 1910.120(q)(9), 1910.120(q)(9)(i)
Whether employees who are verifying that an electrical system is de-energized or are turning off circuit breakers are required to use personal protective equipment 1926.95(a), 1926.416(a), 1926.416(a)(1), 1926 Subpart K
Compliance with electric power generation transmission and distribution requirements for testing of fiberglass insulating tools. 1910.269, 1910.269(j)(1), 1910.269(j)(1)(iii), 1910.269(r)(1)(iv)
Whether employers may designate an outside consultant as the Chemical Hygiene Officer under 1910.1450. 1910.1450, 1910.1450(b)
Storage requirements for discarded filters/pads and for water-filled metal containers in 1910.107. 1910.107, 1910.107(b)(5)(ii)
Whether the material storage requirements in 1926.250(a)(1), (b)(6) and (b)(7) apply to stored and stacked brick and masonry blocks that remain completely secured as shipped (interlocked, banded, shrink-wrapped, or similarly bound for shipment) 1926.250, 1926.250(a)(1), 1926.250(b), 1926.250(b)(6), 1926.250(b)(7)
Clarification of NIOSH's obligation under OSHA to receive and maintain employee exposure and medical records. 1910.1020, 1910.1020(h), 1910.1020(h)(1), 1910.1020(h)(3), 1910.1029(e), 1910.1029(j), 1910.1029(m)(3), 1910.1029(m)(4)
Whether shutting off the truck and disabling controls is a sufficient means of demonstrating that no employee would be endangered under 1910.269(p)(1)(iii). 1910.269, 1910.269(p)(1)(iii)
PSM coverage of utility systems; whether 1910.269 preempts the PSM standard for power generation facilities that serve covered processes. 1910.119, 1910.119(a)(1)(i), 1910.119(a)(1)(ii), 1910.119(b), 1910.119(j)(1), 1910.180(d), 1910.269, 1910.269(a)(1), 1910.269(a)(1)(iii), 1910.269(p)(1)(i)
Use of paper towels instead of electric blow dryers in public restrooms. 1910.141, 1910.141(d)(2)(iv)
Use of a PLC system as an alternative measure which provides effective protection for minor servicing activities. 1910.147, 1910.147(a)(2)(ii), 1910.147(b)
Clarification on trainer requirements and access to trainer under OSHA's bloodborne pathogens standard. 1910.1030, 1910.1030(g)(2)(vii)(N), 1910.1030(g)(2)(viii)
Applicability of OSHA's bloodborne pathogens standard to the containment and disposal of electric razors in correctional facilities and health care settings. 1910.1030, 1910.1030(d)(4)(iii)(A), 1910.1030(d)(4)(iii)(B), 1910.1030(d)(4)(iii)(C), 1910.1030(g)
Clarification of requirements for storage and use of flammable and/or combustible liquids. 1910.106, 1910.106(b), 1910.106(b)(4)(ii), 1910.106(e), 1910.106(e)(2)(ii)(c), 1910.106(e)(2)(iii), 1910.106(e)(2)(iv)(d), 1910.106(e)(3)(v)(a), 1910.106(e)(3)(vi), 1910.106(h)(4)(iii)(a), 1910.119(e)(1), 1910.1000
Clarification of OSHA's requirement for 'quiet time' before audiometric testing. 1910.95, 1910.95(g)(5)(iii)
Whether certain skylights meet the cover criteria of 1926 Subpart M. 1926.501(b)(4), 1926.501(b)(4)(i), 1926.502(i), 1926.502(i)(2), 1926.754(e)(3)(i), 1926.754(e)(3)(iv), 1926 Subpart M
Whether it is permissible for an employee to remain in a trench box when materials are being lowered into it by a backhoe. 1926.651(e)
Are podium ladders covered under 29 CFR 1926 Subpart X or Subpart L? 1926.450(a), 1926.450(b), 1926.452(w), 1926 Subpart L, 1926 Subpart X
Clarification on the requirement for a written opinion from an examining physician.
Clarification of HAZWOPER training requirements as they apply to an employee of the town of Windsor, VT. 1910.120, 1910.120(a)(1), 1910.120(e), 1910.120(e)(1), 1910.120(e)(2), 1910.120(e)(3), 1910.120(e)(4), 1910.120(e)(9), 1910.120(q), 1910.120(q)(6)(ii)