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
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)
Employee's rights upon termination to access to physician's written opinion and respirator fit test results. 4 1926.1101(m)(4), 1910.134(m), 1910.134(m)(2), 1910.134(m)(4)
Request for formal review of Exelon Generating Corporation's energy control procedure. 3 1910.269, 1910.269(d)(8)(ii), 1910.269(d)(8)(ii)(D)
Determining voltage ratings for electrical insulating equipment used during electrical power distribution and transmission work. 8 1910.137(b)(2)(i), 1910.269(a)(3), 1910.269(c), 1910.269(l)(1), 1910.269(l)(2), 1910.269(l)(3), 1910.269(l)(4), 1926.951
Whether ladders must be provided for access/egress for employees climbing columns to make initial connections; whether the initial connection referenced in Question #42 of Directive Number CPL 02-01-034 must be by two wrench-tight bolts? 6 1926.756, 1926.756(a)(1), 1926.1050, 1926.1050(b), 1926.1051, 1926.1051(a)
Conditions under which a stair railing can also serve as a handrail. 3 1910.23(e)(1), 1910.23(e)(2), 1910.23(e)(5)(ii)
Chocking of trailers at United States Postal Service facilities. 3 1910.178, 1910.178(k)(1), 1910.178(m)(7)
Safety precautions, PPE, and immunizations for workers in waste water treatment facility. 1 1910.1030
Revising baseline audiogram when there is a standard threshold shift in only one ear. 2 1910.95(g)(9)(i), 1910.95(g)(10)
Employer obligation to provide access to entire OSHA 300 Logs, including names of both union and non-union employees. 3 1904 - Table of Contents, 1904.29, 1904.35
Acceptability of DOT labeling requirements in lieu of OSHA's labeling requirements for shipments of biohazardous materials. 1 1910.1030(g)(1)(i)
Building owner's requirement to determine and communicate the hazrds from installed ACM and PACM. 4 1926.1101(b), 1926.1101(k)(1), 1926.1101(k)(2), 1926.1101(k)(3)
Applicability of the bloodborne pathogens standard to persons who self-administer injectable medications. 4 1910.1030(b), 1910.1030(d)(2)(i), 1910.1030(d)(2)(vii)(B), 1910.1030(d)(4)(iii)(A)
29 CFR Part 1904 OSHA Recordkeeping Regulation applies only within the jurisdictional boundaries of the United States and certain locations listed in OSHAct Sec. 4(a). 2 1904 - Table of Contents, 1904.5
What OSHA construction standards govern the use of pneumatic hand tools used in construction for cleaning concrete forms, bridge decks and roads? 1 1926.302(b)
Lockout/tagout requirements for servicing manually-controlled vertical/horizontal milling machine and drill press tool changes. 7 1910 Subpart O, 1910 Subpart S, 1910.147, 1910.147(a)(2)(ii), 1910.147(a)(2)(iii)(A), 1910.212, 1910.212(a)(3)(iv)
Revision of the applicability of the steel erection standard to pre-cast concrete erection work interpretation. 1 1926.704(e)
Respirator breathing air cylinders must be maintained in a fully chargd state, regardless of cylinder size, and recharged when pressure falls below 90% of full charge. 1 1910.134(h)(3)(iii)
Approval requirements for replacement, modification, repair, or rehabilitation of electrical utilization equipment. 4 1910.7, 1910.302(b)(2), 1910.303(a), 1910.399
Requirements for step-through fixed ladder side rails that might be used as climbing aid. 2 1910.27, 1910.27(b)(2)