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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How to Request a Letter of Interpretation

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Date Title Standard Number Standard Number
Clarification of the Powered Industrial Truck (1910.178) standard's use of the terms "in need of repair," "defective," and "unsafe." 5 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. 0
The meaning of standards can only be modified through the rulemaking process, not through a letter of interpretation. 1 1926.1053(b)(7)
OSHA jurisdiction over oil and gas pipelines may be preempted by DOT standards. 2 1926.651(b)(2), 1975.1
The construction fall protection standard specifies fall arrest system requirements, but no footwear requirements. 3 1926.501(b)(11), 1926.500(b), 1926.96
Fixed ladders must be retrofitted to meet 1910.27 design requirements; maximum horizontal spacing requirements for extensions. 4 1910.27, 1910.27(d)(1)(i), 1910.27(d)(1)(ii), 1910.27(d)(v)
Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles. 4 1910.1030, 1910.1030(c)(1)(iv)(B), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i)
Requirements for manufacturers, who are no longer in business or have discontinued a product line, to provide MSDSs and product information. 2 1910.1200, 1910.1200(g)(1)
Equipment reverse signal alarms must be audible above surrounding noise level. 4 1926.601(b)(4), 1926.601(b)(4)(i), 1926.601(b)(4)(ii), 1926.602(a)(9)(ii)
Steel erection columns must be anchored by 4 rods and meet 300-lb strength criteria. 3 1926.755(a)(1), 1926.755(a)(2), 1926.752(b)
The use of extension cord while working from scissor lift; requirement to secure or barricade a ladder. 3 1926.451, 1926.452(w), 1926.1053(b)(8)
Training and designation of first aid providers in general industry and construction. 3 1910.151(b), 1910.1030(c)(2), 1926.50(c)
Application of OSHA standards to escape and protection of employees from threats associated with terrorist actions. 2 1910.120(q), 1910.38
Construction of homes with masonry walls is not considered "residential construction" in applying STD 03-00-001. 2 1926.501(b)(13), 1926.502(k)
Maximum allowable distance between supports for temporary electrical wiring. 3 1926.402(a), 1926.403(b)(1), 1926.405(a)(2)
Electrical equipment approved by a NRTL is acceptable to OSHA. 4 1910.7, 1910.303(a), 1910.303(b), 1910.399
Evaluation of the use of aluminum forms as an exit route from trench excavations 2 1926.651, 1926.651(c)(2)
Enforcement of the engineering and work practice control provisions of the lead standard, 1910.1025(e)(1). 2 1910.1025, 1910.1025(e)(1)
Requirements for use of high-visibility warning garments by construction workers in highway work zones. 5 1926.200, 1926.201, 1926.201(a), 1926.200(g)(2), 1926.651(d)
Requirements for providing eyewashes/showers near spray finishing operations. 2 1910.151(c), 1910.107