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
Federal government claims no copyright protection for July 2004 C-DAC Consensus Document.
Clarification of "assigned working hours" for determining recordability of injuries that occur during breaks in the normal work schedule. 1904 - Table of Contents, 1904.5(b)(2)(v)
All prescription medications, including preventive antibiotics, should be considered medical treatment and are recordable. 1904 - Table of Contents, 1904.7
Evaluation of a box van of a truck carrying hazardous materials meeting the definition of a confined space in a hazardous material release/response situation. 1910.146, 1910.120(q)
Network protectors must have the manual override position blocked, locked, or otherwise disabled; must need use of a tool to manually place in closed position. 1910.269(m)(3)(ii)
Inspection requirements for powered industrial trucks not used for significant time periods. 1910.178, 1910.178(q)(7)
Emergency medical services on construction sites 1926.21, 1926.21(b)(2), 1926.50, 1926.50(a), 1926.50(b), 1926.50(c), 1926.50(d), 1926.50(f), 1926.103
Whether under STD 03-00-001 an employee, in absence of interior walls is permitted to climb the lower chords of the roof trusses to brace them. 1926.501(b)(13), 1926.502(k)
Providing employees with toilet facilities on a construction jobsite. 1926.51(c)(1), 1926.51(c)(4)
Evaluation of scenarios regarding PSM requirements related to normally unoccupied remote facilities and natural gas processing plants (gas plant). 1910.119, 1910.119(b)
Request to expand the application of the "de minimis" policy regarding Section 1926.453(b)(2)(iii) and the use of the "Wishbone" fall protection device beyond the parameters described in OSHA's February 2, 2004 letter to Mr. Michael Kurtgis. 1926.453(b)(2)(iii)
Frequency of evaluating audiometric testing rooms to meet the specifications in Appendix D of the Occupational Noise standard. 1910.95(h)(4), 1910.95 App D
OSHA does not test, approve, certify, or endorse any equipment, product, or procedure, including machine design and risk assessment techniques. 1910 Subpart O, 1910.147
MSDS's must be provided to employees who package/process drugs for distribution into final form if they contain hazardous chemicals 1910.1200, 1910.1200(b)(6), 1910.1200(b)(6)(vii), 1910.1200(e)
Audiometric baseline revisions in employee rehire situations. 1910.95
Use of the European Norms and European Community machinery directive to comply with the 1910.212 "General [guarding] requirements for all machines." 1910.212, 1910.212(a)(1), 1910.212(a)(3)
Questions regarding the Permit-Required Confined Space standard, 1910.146, and the Grain Handling standard, 1910.272. 1910.146, 1910.146(c)(2), 1910.272, 1910.272(e)(1)(i), 1910.272(g), 1910.272(g)(3), 1910.272(g)(5)
Requirements of 1926.404(b)(1) application to 208-volt branch circuits; electrical subcontractor requirements under 1926.404(b)(1) to monitor other on-site subcontractors. 1926 - Table of Contents, 1926.404, 1926.404(b)(1), 1926.404(b)(1)(i), 1926.404(b)(1)(ii), 1926.404(b)(1)(iii), 1926.32(f)
Use of personal cooling fans listed for "residential use only" in an industrial setting. 1910.303, 1910.303(b)(2), 1910.399
Documentation methods used to comply with the qualitative evaluation of a range of possible safety/health effects of "failure of controls" requirement of the PSM standard. 1910.119, 1910.119(e), 1910.119(e)(3)