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
Acceptability of using computer-based (on-line) training for the HAZWOPER 40-hour classroom training. 1910.120, 1910.120(e)
Requirements for the sound level of a warning device (horn) located on a forklift 1910.178(q)(7), 1910.178(p)(1), 1910.178(q)(5)
Spray booth requirements including automatic sprinkler systems, relationship to NFPA 33 requirements, and paint storage. 1910.107, 1910.107(a), 1910.107(b)(5)(iv), 1910.107(e)(3), 1910.106(d)(4), 1910.161, 1910.162, 1910.106(a)(18), 1910.106(a)(19)
Evaluation of a personal platform enclosure panel. 1926.1431(e)(6)
Use of manufacturer-applied insulation coating as an insulation barrier; use of equipment within the minimum approach distance with insulation barriers. 1926.550(a)(15), 1926.600(a)(6)
Use of fall protection by deaf employees performing steel erection activities. 1926.750, 1926.750(a), 1926.750(b)(1), 1926.760, 1926.760(a)(1), 1926.760(a)(3), 1926.760(b), 1926.760(c)
Application of the Occupational Noise standard to employees who are deaf or have a diminished capacity to hear. 1910.95, 1910.95(b)(1), 1910.95(i)(2)
OSHA 300 Log requirements versus HIPAA privacy requirements. 1904 - Table of Contents, 1904.35(b)(2)(iv)
Tuberculosis and Respiratory Protection. 1910.134, 1910.134(c), 1910.134(e), 1910.134(f), 1910.134(k), 1910.134(m)
Powered Industrial Trucks: examination prior to being placed in service; evaluations conducted orally versus written; multi-level evaluations; seatbelt use. 1910.178, 1910.178(q)(7), 1910.178(q)(6), 1910.178(l)(1), 1910.178(l)(3)
Requirements for working clearances and spaces around electrical equipment, e.g., ladder cable trays. 1910.303(g), 1910.303(g)(2)(ii), 1910.303(h), 1910.303(h)(2)(ii)
Respiratory protection program requirements for M. tuberculosis based on risk assessments; applicability of the respirator standard to long-term healthcare facilities. 1910.134
Hazard Communication: classification of uninterruptible power source batteries and office chemicals as "consumer products." 1910.1200, 1910.1200(c)
Fall protection requirements for elevated platforms of powered industrial trucks; body belts versus harnesses 1910.178
Requirements in 1926 Subpart L "Scaffolds" regarding the use of plywood to make platform decking for scaffolds. 1926.450(b), 1926.451, 1926.451(a)(1), 1926.451(a)(6), 1926.451(b), 1926.451(f)
Automated External Defibrillator training is not specifically required by the Permit-Required Confined Space standard; AEDs are not required first aid supplies. 1910.146(k)(2)(iii), 1910.151(b)
Clarification of the Powered Industrial Truck (1910.178) standard's use of the terms "in need of repair," "defective," and "unsafe." 1910.178, 1910.178(p)(1), 1910.178(q)(1), 1910.178(p), 1910.178(q)
OSHA's guidelines are advisory, do not create new employer obligations, and are not basis for citations.
The meaning of standards can only be modified through the rulemaking process, not through a letter of interpretation. 1926.1053(b)(7)
The construction fall protection standard specifies fall arrest system requirements, but no footwear requirements. 1926.501(b)(11), 1926.500(b), 1926.96