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
Fall protection requirements for construction workers doing work while on a roof 1926.501(b)(1), 1926.501(b)(10), 1926.501(b)(2), 1926.501(b)(12), 1926.501(b)(13), 1926.502(f)(2)
Requirement to use seat belts during the operation of earthmoving equipment. 1926 - Table of Contents, 1926.602, 1926.602(a), 1926.602(a)(1), 1926.602(a)(2), 1926.602(a)(2)(i), 1926.602(a)(2)(ii), 1926.28(a)
"Threaded studs" are prohibited from being installed prior to decking when they project. 1926.754(c)(1), 1926.754(c)(1)(i)
Fixed industrial stair requirements for access to secondary containment structures surrounding bulk chemical storage tanks. 1910.24, 1910.24(b), 1910.27
Review residential construction scenarios for alternative fall protection procedures. 1926.501, 1926.501(b)(13), 1926.502(k)
Substitution of phosphorescent helmets for retroflective garments does not meet high-visibility clothing requirements for flaggers. 1926.201, 1926.201(a), 1926.200(g)(2)
Modifications or additions to a crane without manufacturer approval where the manufacturer is still in existence. 1926.550(a)(1), 1926.550(a)(16)
Life jacket and skiff requirements when working over or near water. 1926.106, 1926.106(d), 1926.106(a)
Permitted incidental storage of flammable or combustible liquids. 1910.106, 1910.106(e)(2)(i), 1910.106(e)(2)(ii)(b)
Electrical equipment grounding requirements on concrete floors. 1910.304, 1910.304(f)(5)(v)(C)(5), 1910.303(g)(1), 1910.399
Compliance requirements for renovation work involving material containing less than 1% asbestos 1926.1101, 1926.1101(e), 1926.1101(f)(2), 1926.1101(f)(5), 1926.1101(f)(6), 1926.1101(g)(1), 1926.1101(g)(3), 1926.1101(g)(8)(ii), 1926.1101(k), 1926.1101(k)(7), 1926.1101(k)(8), 1926.1101(l)(1), 1926.1101(n)(2)
Application of HAZWOPER (1910.120) to terrorist and weapons of mass destruction incident responses. 1910.120, 1910.120(q)
Building security measures and how they impact the ability of employees to exit a building during an emergency. 1910.35
Permissibility of the welding of joists over 40-feet in length, while the hoisting line is kept in place, instead of field bolting. 1926.757(a)(8), 1926.757(a)(8)(i), 1926.757(a)(8)(ii), 1926.757(b)(3), 1926.757(c)(2)
Clarification of maintenance vs. construction activities; standards applicable to the removal and replacement of steel tanks and structural steel supports. 1926.32(g), 1910.12(a), 1910.12(b), 1926.750(b)(1), 1926.750(b)(2), 1926.750(a), 1926.105, 1910.146
Requirements for attachable scaffold ladders used in construction; toe-hold minimum distance requirement. 1926.451(e), 1926.451(e)(2), 1926.451(e)(2)(i), 1926.451(e)(2)(ii), 1926.451(e)(2)(iii), 1926.451(e)(2)(iv), 1926.451(e)(2)(v), 1926.451(e)(2)(vi), 1926.1053(a)(13)
Fall protection requirements for installing first three rows of roofing or for removing slide guards from a completed roof with a slope 6-in-12 or less. 1926.501, 1926.501(b)(13)
Use of quick disconnect with "pull-down sleeve" to satisfy requirement of a positive means to prevent pneumatic tools from becoming accidentally disconnected 1926.302(b)(1)
Permissibility of installing a trench shield so that the top is flush with the surface. 1926.652, 1926.652(g)(1)(ii)
Employee and employee representative access rights to OSHA 300 Log and OSHA 300-A Summary forms. 1904 - Table of Contents, 1904.35