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
Applicability of HAZWOPER standard to hazardous waste generators that are not conditionally exempt as small quantity generators. 3 1910.120, 1910.120(a)(2)(iii), 1910.120(p)(8)
Highway work zones and reflective/warning vests for the protection of off-duty police officers working as flaggers. 4 1926.200, 1926.200(g)(2), 1926.201, 1926.201(a)
Requirements for carrying and stacking lumber with nails. 2 1926.95(a), 1926.250(b)
OSHA requirements applicable to use of the Contex "Magic Arm" below-the-hook lifting device. 5 1926.20(b), 1926.21(b)(2), 1926.251(a)(1), 1926.753, 1926.1400
Whether OSHA standards prohibit using two power hoists wired together to a single control;whether a minimum of two persons are required to be on board a two-point suspended scaffold. 3 1926.451, 1926.451(d)(13), 1926.452
The powered platform standard's emergency action plan requirements do not necessarily require lowering the platform to ground level. 2 1910.66, 1910.66(e)(9)
Interlock requirements for access door(s) of trash compactor. 3 1910.147, 1910.147(a)(2)(ii), 1910.212
Correct manner to interpret air sample measurements of an employee's asbestos exposure when the samples are overloaded. 3 1926.1101, 1926.1101(c)(1), 1926.1101(f)(1)
Requirements for providing awareness training for employees performing housekeeping duties; providing notification of ACM/PACM for employers and employees. 5 1910.1001, 1910.1001(j)(2)(iii), 1910.1001(j)(7)(iv), 1926.1101, 1926.1101(k)(2)(ii)
Employer's obligation to assure the accuracy of the sharps injury log. 4 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(f)(3), 1910.1030(h)(5)
29 CFR 1926.651(i)(1); excavation operations. 1 1926.651(i)(1)
Requirement for a safety latch on a sling hook depends on the activity for which the sling is being used. 7 1910.181(a)(29), 1910.181(j)(2), 1910.184(c)(6), 1917.45, 1918.66, 1918.81, 1926.753
OSHA's machine guarding requirements provide no exemption from guarding based on shaft size or speed. 2 1910.219(c)(2)(i), 1910.219(c)(5)
Notification requirements for concrete compressive strength and anchor bolt modifications. 5 1926.752(a), 1926.752(a)(2), 1926.752(b), 1926.755(b), 1926.755(b)(2)
Use of passing trays and single-handed scalpel blade remover in a surgical setting. 3 1910.1030, 1910.1030(c)(1)(iv), 1910.1030(d)(2)
Rail extensions for a portable ladder;step-through ladder device. 2 1926.1053(b)(1), 1910.25(d)(2)
Determining if an injury is considered a new recordkeeping case based on a recurrence of previously recorded symptoms. 3 1904 - Table of Contents, 1904.5(b)(3), 1904.6
Whether gas-actuated fastening tools require the same individual training for each model as powder-actuated fastening tools. 3 1926.21(b)(2), 1926.302(e), 1910.243(d)
Clarification of the retail facilities exemption under the PSM standard. 2 1910.119, 1910.119(a)(2)(i)
"Freehand" piercing without the use of forceps or other engineering controls violates the bloodborne pathogens standards. 2 1910.1030, 1910.1030(d)(2)(i)