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
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)
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
Requirements for fall protection when ladder jack scaffolds are used for residential and commercial construction 1926.451, 1926.451(g)(1), 1926.451(g)(1)(i), 1926.452, 1926.452(k)(1), 1926.500, 1926.500(a)(2)(i), 1926.501, 1926.501(b), 1926.501(b)(12), 1926.501(b)(13), 1926.501(b)(2), 1926.502, 1926.502(k), 1926.760
Marking and proof-testing requirements for special custom-designed lifting accessories. 1926.251, 1926.251(a), 1926.251(a)(4)
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)
Maximum intervals for providing fixed-ladder landing platforms used in General Industry. 1910.27, 1910.27(d)(2)
Fall protection requirements for homes built of block and masonry construction. 1926.501, 1926.501(b), 1926.501(b)(13), 1926.502, 1926.502(k)
Electronic Mail Systems and Bloodborne Pathogens Training requirements. 1910.1030, 1910.1030(g)(2)(vii)(N), 1910.1030(g)(2)(viii)
Enforcement of manhole step specification requirements during rulemaking proceedings. 1910.27
Requirements for emergency response and planning under the Process Safety Management Standard. 1910.38(a), 1910.38(c)(3), 1910.119(n), 1910.120(a), 1910.120(q), 1910.120(q)(1), 1910.120(q)(6)(ii), 1910.120(q)(6)(iii)
Participation by professional sports teams in the Bureau of Labor Statistics Survey of Occupational Injuries and Illnesses; definition of independent contractor versus employee. 1904 - Table of Contents, 1904.31
Recording criteria for cases involving workers from a temporary help service, employee leasing service, or personnel supply service. 1904 - Table of Contents, 1904.29, 1904.31, 1904.33, 1904.35, 1904.40, 1904.46
Immunizations or inoculations (except tetanus) are recordable when given in response to a workplace injury or illness. 1904 - Table of Contents, 1904.7(b)(5)(ii)(B)
Response to Edison Electric Institute's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard." 1910.269, 1910.269(d), 1910.269(d)(8)(v), 1910.146, 1910.147
Response to Exelon Generation's concerns regarding draft Instruction CPL 2-1.18A, "Enforcement of the Electric Power Generation, Transmission and Distribution Standard." 1910.269, 1910.269(d), 1910.269(d)(8)(v), 1910.147
Clarification on the USPS's lockout/tagout procedures and minor servicing operations for the multiple line optical character recognition sorter. 1910.147, 1910.147(a)(2)(ii)
Storage of materials that prevents inspection of scaffolds before workshifts; incidental storage amounts that do not inhibit scaffold inspection. 1926.250, 1926.250(b)(5), 1926.451, 1926.451(b)(9), 1926.451(f)(3)
Employer's responsibility to protect employees from workplace hazards through appropriate hazard control methods 1910.106, 1910.106(b)(6), 1910.1000
Potential exposure to contaminated sharps in the solid waste industry. 1910.1030, 1910.1030(c)(2)(i)