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

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Date Title Standard Number Standard Number
Clarification of OSHA requirements for trainer qualifications under the HAZWOPER standard. 3 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. 1 1926.751
Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss. 4 1904 - Table of Contents, 1904.5, 1904.10, 1910.95
"Scaffolds" 1 1926 Subpart L
Clarification of the phrase "when required" as used specifically in 29 CFR 1910.28. 4 1910.28, 1910.28(a)(17), 1910.28(c)(14), 1910.28(d)(7)
Discussion of the Energy Employees Occupational Illness Compensation Program Act as administered by the DOL. 0
Requirements for the construction of trash receptacles used in operating rooms for the containerization of regulated waste. 4 1910.1030, 1910.1030(d)(4)(iii)(B)(1), 1910.1030(d)(4)(iii)(B)(2), 1910.1030(g)(1)(i)
Determining the presence of blood in mixture that comprises raw sewage. 3 1910.132, 1910.1030, 1910.1030(b)
Clarification of an alleged OSHA statement regarding foot protection in the USPS safety program. 2 1910.136(a), 1910.136(b)(1)
Whether reclassification is available for permit-required confined spaces with potentially hazardous atmospheres. 3 1910.146, 1910.146(c)(7), 1910.146(d)(3)
Fall protection for a fixed platform mounted vehicle and an aerial lift. 0
Whether an employer is required to start over an incompleted Hepatitis B vaccination series. 3 1910.1030, 1910.1030(f)(1)(ii)(D), 1910.1030(f)(2)(i)
Application of OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, to employees in wastewater treatment plants. 5 1910.1030, 1910.1030(a), 1910.1030(b), 1910.1030(c)(2), 1910.1030(f)
Requirements for annual refresher training under OSHA's HAZWOPER standard. 5 1910.120(q), 1910.120(q)(6), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii), 1910.120(q)(8)
Clarification on whether to use quantitative or qualitative fit-testing for full-facepiece PAPRs. 2 1910.134, 1910.134(f)(8)
Cross-member supports used for climbing communication towers are not fixed ladders under 1910.268(h). 4 1910.21, 1910.21(e)(1), 1910.268, 1910.268(h)(2)
Small farming operations and exemption from OSHA enforcement activity under CPL 02-00-051. 1 1928.21
Requirement for employer to assess potential hazards of handling trailer debris to provide necessary PPE and hazard communication information to affected employees. 4 1910.120(q), 1910.132, 1910.134(a)(2), 1910.1200
Motor vehicle requirements for a re-paving project. 2 1926.601, 1926.601(a)
Whether diabetics who self-administer at work can dispose of capped insulin syringes in an office trash container. 2 1910.1030, 1910.1030(d)(4)(iii)(A)