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
Whether OSHA requirements prohibit working from a portable stepladder and, if not, whether fall protection is required. 29 CFR 1926.1053(b). 1926 - Table of Contents, 1926.500(a)(2)(vii), 1926 - Table of Contents, 1926.1053(b), 1926.1053(b)(3), 1926.1053(b)(4), 1926.1053(b)(13), 1926 Subpart M, 1926 Subpart X
Whether under 1926.550, a crane may be left unattended with its spreader bar suspended; where in 1926.550 of Subpart N, other than in 1926.550(g), is the use of tag lines referenced; how are "cable lugs" used under 1926.351(b)(3). 1926.351(b), 1926.351(b)(3), 1926.550, 1926.550(b)(2), 1926.550(g), 1926 Subpart N
Whether the "Clear Gear Lanyard Elevator" conforms to OSHA construction standards. 1926.502, 1926.502(d)
Whether crane lifting devices are considered to be part of the load and are allowed to be hoisted over personnel. 1910.179, 1910.179(n)(3)(vi)
Glove bag requirements for outdoor removal of intact and non-intact asbestos-containing gaskets under 1926.1101. 1926.1101, 1926.1101(b), 1926.1101(g)(4)(ii)(A), 1926.1101(g)(4)(ii)(B), 1926.1101(g)(5), 1926.1101(g)(8)(iv)(A), 1926.1101(g)(9), 1926.1101(g)(9)(i), 1926.1101(g)(9)(iv), 1926.1101(g)(9)(v)
Clarification on OSHA's enforcement policy for fixed ladders. 1910.27, 1910.27(d)(1)(i), 1910.27(d)(1)(ii), 1910.27(d)(5)
Requirement to determine, in advance, whether employees are likely to disturb ACM or PACM and to train accordingly. 1910.1001, 1915.1001, 1926.1101
Determining whether injuries in the company parking lot during paid company break are work-related. 1904 - Table of Contents, 1904.5
OSHA does not regulate the final disposal of medical waste. 1910.1030, 1910.1030(d)(4)(iii)(A), 1910.1030(d)(4)(iii)(C)
Clarification of PPE requirements for phlebotomists performing venipunctures in hospital setting and/or rural outpatient clinics. 1910.1030, 1910.1030(b), 1910.1030(c)(2)(i), 1910.1030(d)(1), 1910.1030(d)(3)(ix), 1910.1030(g)(2)(vii)(E), 1910.1030(g)(2)(vii)(F), 1910.1030(g)(2)(vii)(G)
OSHA requirements for crane operators. 1926 Subpart N
Clarification of the 1910.269 requirement for the presence of at least two "qualified" employees for work on exposed energized lines. 1910.269, 1910.269(a)(2)(i), 1910.269(a)(2)(ii), 1910.269(b), 1910.269(g)(2)(v), 1910.269(l)(1)(i), 1910.269(v), 1910.269(x)
Applicability of OSHA's bloodborne pathogens standard to the use of safety needles with self-infuse bleeding products. 1910.1030
Whether it is permissible to anchor a fall arrest system at an employee's feet. 1926.502(d)(16), 1926.502(d)(16)(iii)
Whether "discriminating [back-up] alarms" may be used to meet the requirements of 29 CFR 1926.602(a)(9)(ii). 1926.602, 1926.602(a), 1926.602(a)(9), 1926.602(a)(9)(ii)
Clarification of OSHA requirements for trainer qualifications under the HAZWOPER standard. 1910.120, 1910.120(e), 1910.120(e)(5)
Clarification of OSHA requirements for trainer qualifications under the HAZWOPER standard. 1910.120, 1910.120(e), 1910.120(e)(5)
Distinction between "column" and "post" in the Safety Standards for Steel Erection, 29 CFR 1926 SubpartR. 1926.751
Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss. 1904 - Table of Contents, 1904.5, 1904.10, 1910.95
"Scaffolds" 1926 Subpart L