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
12/09/2004	Needle removal procedures for situations where other methods of disposal are infeasible or required by a specific procedure.	3	1910.1030(d)(1)(ii)(B), 1910.1030(d)(2)(vii)(A), 1910.1030(d)(2)(vii)(B)
12/07/2004	LOTO: Use of heavy-duty nylon cable ties as lockout devices in lieu of chains and locks.	4	1910.147, 1910.147(c)(5)(i), 1910.147(c)(3), 1910.147(c)(5)
12/06/2004	Compliance of automatically retractable rest platforms used with self-retracting lifelines for meeting requirements for fixed ladder safety equipment.	5	1926.1053(a)(19), 1926.1053(a)(19)(i), 1926.1053(a)(19)(ii), 1926.1053(a)(19)(iii), 1926.1050(b)
11/30/2004	Determination of the date of an injury or illness for OSHA recordkeeping purposes.	2	1904 - Table of Contents, 1904.6(a)
11/30/2004	Residential fall protection: safety monitors; walking top plate of braced walls in installation; warning line; plating exterior walls; height limitation; non-roofer PPE; slide guards	11	1926.502, 1926.502(h), 1926.502(h)(1), 1926.502(h)(1)(i), 1926.502(h)(1)(ii), 1926.502(h)(1)(iii), 1926.502(h)(1)(iv), 1926.502(h)(1)(v), 1926.502(k), 1926.501(b)(10), 1926.501(b)(13)
11/23/2004	Conditions under which use of powered industrial truck not designated EX can be used in atmospheres containing carbon black.	2	1910.178, 1910.178(c)(2)(ii)(a)
11/17/2004	Duty of a subcontractor to cover floor holes in a Multi-Employer work site.	9	1926.501(b)(4), 1926.501(b)(4)(i), 1926.501(b)(4)(ii), 1926.501(b)(4)(iii), 1926.502(i), 1926.501, 1926.502(i)(2), 1926.502(i)(3), 1926.502(i)(4)
11/17/2004	Acceptability of using a sleeve to anchor a column; protection from hazard of swaying columns.	2	1926.755(a)(1), 1926.755(a)(2)
11/17/2004	Determining the need for hard hat and eye protection on construction sites.	7	1926.100, 1926.100(a), 1926.102(a), 1926.95, 1926.95(a), 1926.28(a), 1926.102(a)(1)
11/12/2004	Posting requirements for notices in other languages.	1	1903.2
11/10/2004	Recognition of ANSI/ASSE Z244.1 "Control of Hazardous Energy - Lockout/Tagout and Alternative Methods" consensus standard	3	1910.6, 1910.147, 1910.147(c)(4)(ii)
11/05/2004	Powered Industrial Truck 1910.178(l) training requirements applicable to construction; training for skid-steer loader operators.	7	1910.178, 1910.178(a), 1910.178(l), 1926.20(b)(4), 1926.21(b)(2), 1926.602(a), 1926.602(d)
11/04/2004	Evaluation of what is considered a safe speed to operate powered industrial trucks (forklifts)	2	1910.178(n)(8), 1910.178(n)(15)
11/04/2004	OSHA does not enforce NFPA 70E, although it may use NFPA 70E to support citations relating to certain OSHA standards.	1	1910.335
10/28/2004	Requirements for providing medical evaluations prior to wearing respiratory protection for training exercises.	2	1910.134, 1910.134(e)
10/28/2004	Top rail and handrail requirements for stairrail systems under the construction standards.	6	1910.23(e)(1), 1910.24(h), 1926.1052, 1926.1052(c)(6), 1926.1052(c)(7), 1926.1052(c)
10/21/2004	Respiratory protection medical evaluations: additional evaluations; use of employee's physician; testing; medical removal; and confidentiality.	3	1910.134, 1910.134(c), 1910.134(e)(5)
10/20/2004	LOTO: minor servicing exemption and the use of a lockable on/off switch as an alternate measure to provide effective protection.	2	1910.147, 1910.147(a)(2)(ii)
10/18/2004	Requirements for fit testing employees before fire brigade training exercises.	2	1910.134, 1910.134(f)
10/12/2004	Evaluation of using a curbing system for a land crane on a barge to meet the requirements to positively secure the crane to the barge.	2	1926.550(f), 1926.550(f)(1)(iv)