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
Response to concerns about unsafe and unsanitary conditions within the meatpacking industry. 1908.1
Engineering control requirements for allergy and immunization injections. 1910.1030, 1910.1030(b), 1910.1030(d)(2)(i), 1910.1030(c)(1)(v), 1910.1030(c)(1)(iv)
Results of an MRI do not negate the recordability of a physician's recommendation. 1904 - Table of Contents, 1904.7
Batteries in powered industrial trucks must be secured horizontally and/or vertically 1910.178, 1910.178(g)(5)
OSHA enforcement policy of the PSM standard distilleries and related facilities in SIC 2085. 1910.119, 1910.106, 1910.119(a)(1)(ii)(B), 1926.64(a)(1)(ii)(B)
Employee access to needlestick and contaminated sharps injury log requirements. 1910.1030, 1904.35(b)(2), 1904.8
Enhanced Enforcement Policy for Employers Who Are Indifferent to Their Obligations Under the OSHAct. 1903 - Table of Contents, 1903.19
Beards may not interfere with face seal;alternative respirators for bearded employees. 1910.134, 1910.134(d)(1)(i), 1910.134(g)(1)(i)
Employee and employee representative access to MSDS; accompanying CSHOs on inspections. 1910.1200, 1903 - Table of Contents, 1910.1200(g)(8), 1903.8, 1903.8(a), 1903.8(b), 1903.8(c), 1903.8(d)
Workplace exposure limits for ultra-violet radiation 1910.97, 1910.1096
Application of absorbent pads for spill control;hazardous waste site cleanup training does not qualify worker as hazardous materials technician. 1910.120, 1910.120(q)(6), 1910.120(e)
Retesting of reassembled lifting accessories if original manufacturing controls are ensured; retesting requirement if repair/replacement of parts due to breakage, damage, or evidence of diminished capacity. 1926.251, 1926.251(a)(4)
Tunnel/Underground construction requirements: use of flexible bag lines for ventilation; location of main ventilation fan; and reversible ventilation 1926 - Table of Contents
Reiteration of Existing OSHA Policy on Indoor Air Quality: Office Temperature/Humidity and Environmental Tobacco Smoke 1910.1000
Needlestick Safety and Prevention Act and the requirement to include safety-engineered sharps devices in pre-packaged surgical kits or trays. 1910.1030, 1910.1030(d)(2)(i), 1910.1030(c)(1)(v)
Clarification of PSM applicability to processes that are based partly or solely on quantities in connected atmospheric storage tanks. 1910.119, 1910.119(a)(1)(ii)(B), 1910.1450
Enforcement Policy for Respiratory Hazards Not Covered by OSHA Permissible Exposure Limits. 1910.1000, 1910.5(f)
Use of occupational exposure levels (OELs) for substances not covered by an OSHA Permissible Exposure Limit (PEL). 1910.1000
Evaluation of sutureless catheter securement devices to prevent needlestick hazards. 1910.1030(c), 1910.1030
Sheer connector requirements in the steel erection standard to bridge repair/rehabilitation. 1926.750, 1926.750(a), 1926.750(b)(1), 1926.750(b)(2), 1926.754, 1926.754(c)(1)