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
Questions and answers about color coding machine and machine guards according to ANSI Z535.1-1990 1910.144, 1910.144(a)(3), 1910.219, 1910.219(p)(1), 1910.219(p)(2), 1910.219(p)(3), 1910.219(p)(4), 1910.219(p)(5), 1910.219(p)(6), 1910.219(p)(7)
Recapping of contaminated needles used in body piercing. 1910.1030, 1910.1030(d)(2)(i), 1910.1030(d)(2)(vii), 1910.1030(d)(4)(iii)(A)(1)
Retesting requirements if employee's annual audiogram shows a Standard Threshold Shift (STS). 1910.95, 1910.95(g)(7)(ii)
Firefighter training requirements to respond to emergency releases, or potential emergency releases, of hazardous substance. 1910.120, 1910.120(q)(6)(ii)
Regulations related to liquid asphalt and to marine barge slips. 1910.106, 1910.106(a)(18)(ii)(b)
Relevance of NFPA 70E industry consensus standard to OSHA requirements; whether OSHA requirements apply to owners. 1926.402(a), 1910.132, 1910.335, 1926.403, 1926.404, 1926.405, 1926.406, 1926.407, 1926.408, 1910.303(f), 1926.403(h), 1910.12
Powered Industrial Truck (forklift) operator trainer qualifications. 1910.178, 1910.178(l)(2)(iii)
Clarification of Recordkeeping's work-related exception. 1904 - Table of Contents, 1904.5(b)(2)
Permissibility of using guardrail systems other than perimeter safety cables in steel erection. 1926.760(a)(1), 1926.760(a)(2), 1926.760(a)(3)
OSHA policy on using wipe sampling for 4,4' methylenedianiline (MDA) as the basis for enforcement action. 1910.1050, 1910.1050(b), 1910.1050(f)(1)(ii), 1910.1050(l)(1), 1910.1050(l)(2), 1910.1050(l)(3)
Acceptability of rhodizonate-based spot test kits for determining the presence or absence of lead in paint coatings. 1910.1025, 1926.62
Fall protection requirements during installation and removal or tarps and sheeting on/from scaffolds; qualifications of person determining safety on scaffold with wind imposed forces. 1926.451(g)(2), 1926.451(f)(12), 1926.451(g)(1), 1926.451(a)(6), 1926.451(f)(3), 1926.450
Workplace use of electrical equipment designated as "Household Use Only" and recordkeeping requirements. 1910.303(a), 1910.303(b)(2), 1910.7, 1910.303(b), 1910.304(f)(5)(v)(C)(5)
Motor-control-circuit switches and relays are prohibited from being used as energy isolating devices. 1910.147, 1910.147(c)(1), 1910.147(a)(2)(ii)
CSHO use of external GFCI testers to enforce 29 CFR 1926.404(b)(1) 1926.404, 1926.404(b)(1), 1926.404(b)(1)(i), 1926.404(b)(1)(ii), 1926.404(b)(1)(iii)
Clarification of 1926.502(d)(6) term "designed for" in snaphook connections. 1926.502, 1926.502(d), 1926.502(d)(6)
Acceptable methods to locate underground utility installations; evaluation of hydro-vacuum excavation. 1926.651, 1926.651(b)(2), 1926.651(b)(3)
Use of approved GFCI's that do not have open-neutral protection. 1926.404(b)(1)(i), 1926.404, 1926.404(b), 1926.404(b)(1)(ii), 1926.449
Storage of Class IA and IB flammable liquids in glass containers. 1910.106, 1910.106(d)(2), 1910.106(d)(2)(iii)(a), 1910.106(d)(2)(iii)(a)(2)
Marking and proof-testing requirements for special custom-designed lifting accessories. 1926.251, 1926.251(a), 1926.251(a)(4)