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 "potential atmospheric hazard" when reclassifying a PRCS as a non-permit required confined space. 3 1910.146(b), 1910.146(c)(7), 1910.146(c)(7)(i)
Qualifications for interpreting/classifying chest roentenograms and maintenance of interpretation forms. 6 1910.1001, 1910.1001(m)(3), 1910.1001(m)(5), 1910.1020, 1910.1020(d)(1), 1910.1020(d)(1)(i)
Clarification on recording days away from work for follow-up visits to doctor while on restricted-duty job and recovery time to stabilize preexisting condition. 2 1904 - Table of Contents, 1904.5(b)(2)(ii)
Fall protection requirements for workers on guardrail-equipped platforms. 2 1926.451(g)(1), 1926.451(g)(4)
Use of ANSI/ISA S84.00.01-2004 Parts 1-3 (IEC 61511 MOD) to comply with OSHA's Process Safety Management standard 1 1910.119
Enhanced risk of damage/degradation of insulation integrity on temporary wiring with prolonged use 1 1910.269
Clarification of "continuous forced air ventilation" for PRCS entry work. 2 1910.146(c)(5)(i), 1910.146(c)(5)(ii)(E)
A worm drive gearbox is not considered to be a holding brake. 4 1910.179, 1910.179(a)(2), 1910.179(f)(1)(i), 1910.179(f)(1)(ii)
Once medical treatment beyond first aid has occurred for injury or illness the case must be recorded. 2 1904 - Table of Contents, 1904.7(b)
Acceptability of slip on fittings on stair rails and requirement for stair rails to be smooth surfaced. 2 1910.23, 1910.23(e)(1)
OSHA regulations applicable to materials used on asphalt tank farms. 1 1910.106
Periodic serologic testing to monitor antibody concentrations after completion of the hepatitis B vaccine three-dose series is not recommended. 2 1910.1030, 1910.1030(f)(1)(i)
Whether 29 CFR 1926.601 prohibits an employer from leaving light duty pick-up trucks running and unattended on an off-highway jobsite. 2 1926.600(a)(3)(ii), 1926.601
The requirements for vehicle-mounted elevating and rotating aerial devices; effect of revised ANSI A92.2 standards. 2 1926.453, 1926.453(a)(1)
Chocking requirements for trailers docked to buildings with downward approaches. 3 1910.178, 1910.178(k)(1), 1910.178(m)(7)
Definition of "extreme low position" for overhead and gantry cranes. 2 1910.179, 1910.179(h)(2)(iii)(a)
Slip resistance of skeletal structural steel. 2 1926.754, 1926.754(c)(3)
CPR training is a required element in some OSHA general industry standards. 4 1910.151(b), 1910.146, 1910.266, 1910.269
Acceptability of using a light switch as a disconnecting means for the electrical lockout/tagout standard. 5 1910.303(b)(2), 1910.333(a)(2), 1910.333(b)(1), 1910.333(b)(2), 1910.399
Training programs for the Control of Hazardous Energy (LOTO) and for the Hazard Communication standard are not satisfied solely by merely providing employees written documentation. 4 1910.147, 1910.147(c)(7)(i), 1910.1200, 1910.1200(h)