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
Clarification of several recordkeeping scenarios regarding the use of prescription medication in treating a work-related case. 2 1904 - Table of Contents, 1904.7
Whether to record injuries that occur to a contract employee when traveling from an offshore manned platform complex to other downfield fixed platforms. 3 1904 - Table of Contents, 1904.5, 1904.31
Whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms. 2 1904 - Table of Contents, 1904.5
Clarification on providing first aid training and maintenance of medical records under OSHA's BBP standard. 4 1910.151, 1910.151(b), 1910.1030, 1910.1030(h)(1)(ii)(A)
OSHA's requirement to provide first aid supplies specific to the needs of the workplace. 2 1910.151, 1910.151(b)
Whether urine containers and pregnancy tests need to be discarded in biohazard containers. 1 1910.1030(b)
Detachable vs. permanent side shields for safety glasses; modifications to safety glasses. 6 1910.6, 1910.333, 1910.133(a)(2), 1910.133(b)(1), 1915.153, 1915.153(a)(2)
Whether shielding is required when removing Becton Dickinson's blood tubes with a Hemoguard® closure. 3 1910.1030, 1910.1030(d)(2)(i), 1910.1030(d)(3)(x)
Re: Subpart L; scaffolds; Companion Rail, rail extensions for mobile scaffolds; 1926.451. 6 1926.451, 1926.451(a), 1926.451(g)(1), 1926.451(g)(4)(i), 1926.452, 1926.452(w)
Responsibility of chemical manufacturers and importers to provide MSDSs to one or more establishments owned and managed by same employer. 2 1910.1200, 1910.1200(g)(6)(i)
Wearing short-sleeved shirts while performing a thermal spray operation with exposure to hexavalent chromium fumes. 2 1910.132, 1910.1026(h)(1)
Acceptable time lapse for "annual" training. 2 1910.1030, 1910.1030(g)(2)(v)
Locked first aid cabinets in the workplace. 1 1910.151(b)
The use of safety-engineered devices and work practice controls in operating rooms; hospital responsibility to protect independent practitioners under BBP standard. 2 1910.1030, 1910.1030(c)(1)(iv)
Requirement for facility owners to notify tenants or employers of presence of ACM and PACM. 5 1910.1001, 1910.1001(j)(2)(iii), 1926.1101, 1926.1101(k)(2)(i), 1926.1101(k)(2)(ii)(D)
OSHA requirements for providing training for first aid, CPR, and BBP for prompt treatment of injured employees at various workplaces. 11 1910.151, 1910.151(b), 1910.266, 1910.266(i)(7), 1910.269, 1910.269(b), 1910.1030, 1910.1030(b), 1910.1030(g)(2), 1926.50, 1926.50(c)
Whether §1926.550(g) applies to boom-attached personnel lifting platforms and, if not, whether OSHA requires proof testing of such platforms; what is the meaning of "at each new job site" in ASME B30.23; and what standards apply to derrick mounted bu 5 1926.550, 1926.550(a), 1926.550(a)(1), 1926.550(g), 1926 Subpart N
Annual BBP training requirement for employees who have been provided more stringent training under 32 CFR Part 627 and the CDC-NIH BMBL publication. 2 1910.1030, 1910.1030(g)(2)(ii)
Whether dental anesthetic carpules are considered to be "contaminated sharps" or "regulated waste". 4 1910.1030, 1910.1030(b), 1910.1030(d)(4)(iii)(A), 1910.1030(d)(4)(iii)(B)
Use of rapid HIV antibody testing on a source individual after an exposure incident. 2 1910.1030, 1910.1030(f)(3)(ii)(A)