Letters of Interpretation | Occupational Safety and Health Administration

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
12/28/2006	Application of the Lockout/Tagout standard to die-setting activities and other machine setup operations.	5	1910.147, 1910.147(a)(2)(ii), 1910.147(a)(2)(iii)(A), 1910.147(b), 1910.212
12/19/2006	"Continuous industrial processes" and the infeasibility of de-energizing equipment under 29 CFR 1910.333.	2	1910.333, 1910.333(a)(1)
11/30/2006	Clarification of use of the annual audiogram in place of the baseline.	2	1910.95, 1910.95(g)(9)
11/29/2006	Whether inspections for portable fire extinguishers can be reduced from monthly to quarterly intervals.	6	1910.155, 1910.155(c)(27), 1910.157, 1910.157(d)(3), 1910.157(e), 1910.157(e)(2)
11/21/2006	Qualifications required under 1910.269 for entry into manholes/vaults to perform work on energized conductors.	8	1910.146, 1910.269, 1910.269(a)(2), 1910.269(a)(2)(ii), 1910.269(e)(2), 1910.269(l)(1), 1910.269(l)(2), 1910.269(t)
11/14/2006	OSHA requirements for warning signs and protection from electric-arc-flash hazards and compliance with NFPA 70E-2004.	17	1910.5, 1910.5(c)(1), 1910.5(f), 1910.132, 1910.145, 1910.303, 1910.303(e), 1910.333, 1910.333(a)(1), 1910.333(b)(2), 1910.335, 1910.335(b), 1910.335(b)(1), 1910.335(a)(1)(iv), 1910.335(a)(1)(v), 1910.335(a)(2)(i), 1910.335(a)(2)(ii)
11/14/2006	Use of "objective data" to accurately characterize employee exposures to hexavalent chromium during welding operations	2	1910.1026(d)(3), 1926.1126(d)(3)
11/13/2006	Notification of alternative control methods for Class I asbestos work no longer required; notification requirement eliminated.	1	1926.1101
11/01/2006	Updating the OSHA 300 Log to show changes in classification of previously recorded injuries/illnesses.	2	1904 - Table of Contents, 1904.33
10/31/2006	Clarification of the Hexavalent Chromium Final Rule	8	1910.1026, 1910.1026(e), 1910.1026(f)(2), 1910.1026(h), 1910.1026(i), 1910.1026(j), 1910.1051(e), 1910.1052(e)
10/19/2006	Use of live-line tools and exemption to the requirement for at least two employees to be present during work on an energized part.	9	1910.137, 1910.269(j), 1910.269(l)(1)(i), 1910.269(l)(1)(ii), 1910.269(l)(2), 1910.269(l)(3), 1910.269(m), 1910.269(m)(1), 1910.269(n)
10/19/2006	Fall protection requirements for tankers/trailers and OSHA jurisdiction over facilities regulated by DOE.	0
10/18/2006	Incorporation of NFPA 70E-2000 into OSHA standards.	1	1910 Subpart S
10/11/2006	OSHA standards do not apply to state university employees.	0
10/11/2006	Federal OSHA has no jurisdiction over State, municipal, or volunteer fire departments.	0
10/11/2006	Use of LOTO device on equipment placed in "out of service" status not related to servicing or maintenance.	3	1910.147, 1910.147(a)(1)(i), 1910.147(c)(5)(ii)
10/04/2006	Requirements for embroidery on flame-resistant clothing under 29 CFR 1910.269.	2	1910.269, 1910.269(l)(6)(iii)
09/28/2006	Guarding requirements for skylights and "grandfather" provisions for buildings constructed over twenty years ago.	2	1910.23, 1910.23(a)(4)
09/28/2006	Lockout and tagging of circuits; §1926.417	4	1926.417, 1926.417(a), 1926.417(b), 1926 Subpart K
09/21/2006	Requirements for developing entry procedures for permit-required confined spaces.	5	1910.146, 1910.146(c)(2), 1910.146(c)(3), 1910.146(c)(8), 1910.146(d)(3)