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
Determination of the date of an injury or illness for OSHA recordkeeping purposes. 1904 - Table of Contents, 1904.6(a)
Conditions under which use of powered industrial truck not designated EX can be used in atmospheres containing carbon black. 1910.178, 1910.178(c)(2)(ii)(a)
Determining the need for hard hat and eye protection on construction sites. 1926.100, 1926.100(a), 1926.102(a), 1926.95, 1926.95(a), 1926.28(a), 1926.102(a)(1)
Acceptability of using a sleeve to anchor a column; protection from hazard of swaying columns. 1926.755(a)(1), 1926.755(a)(2)
Duty of a subcontractor to cover floor holes in a Multi-Employer work site. 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)
Posting requirements for notices in other languages. 1903.2
Recognition of ANSI/ASSE Z244.1 "Control of Hazardous Energy - Lockout/Tagout and Alternative Methods" consensus standard 1910.6, 1910.147, 1910.147(c)(4)(ii)
Powered Industrial Truck 1910.178(l) training requirements applicable to construction; training for skid-steer loader operators. 1910.178, 1910.178(a), 1910.178(l), 1926.20(b)(4), 1926.21(b)(2), 1926.602(a), 1926.602(d)
Evaluation of what is considered a safe speed to operate powered industrial trucks (forklifts) 1910.178(n)(8), 1910.178(n)(15)
OSHA does not enforce NFPA 70E, although it may use NFPA 70E to support citations relating to certain OSHA standards. 1910.335
Top rail and handrail requirements for stairrail systems under the construction standards. 1910.23(e)(1), 1910.24(h), 1926.1052, 1926.1052(c)(6), 1926.1052(c)(7), 1926.1052(c)
Requirements for providing medical evaluations prior to wearing respiratory protection for training exercises. 1910.134, 1910.134(e)
Respiratory protection medical evaluations: additional evaluations; use of employee's physician; testing; medical removal; and confidentiality. 1910.134, 1910.134(c), 1910.134(e)(5)
LOTO: minor servicing exemption and the use of a lockable on/off switch as an alternate measure to provide effective protection. 1910.147, 1910.147(a)(2)(ii)
Requirements for fit testing employees before fire brigade training exercises. 1910.134, 1910.134(f)
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. 1926.550(f), 1926.550(f)(1)(iv)
Loads must be attached to the block hook by a sling or other approved device and may not be attached directly to the running rope. 1910.179, 1910.179(n)(2)(i), 1910.179(n)(2)(ii)
Grounding requirements for aerial lifts (bucket trucks) under the General Industry 1910.269 and Construction 1926.952 standards. 1910.269, 1910.269(n)(6), 1910.269(n)(7), 1910.269(l)(2), 1926.950(c), 1926.952(b)(2), 1926.954(e)(1), 1926.954(e)(2)
Ladder safety requirements for towers more than 20 feet in length: sliding fall protection devices, safety cages/wells, landing platform intervals. 1910.27, 1910.27(d)(5), 1910.27(d)(1)(ii), 1910.27(d)(2), 1910.23
Clarification if a depression constitutes a hole or unprotected side/edge and associated fall protection requirements. 1926.500(b), 1926.501(b)(1), 1926.501(b)(4)(i), 1926.501(b)(4)(ii), 1926.502(b)