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
Acceptability of using a straight needle where there's no exposure to blood or OPIM. 1910.1030
Acceptability of climbing over or through guardrails on scaffolds used in construction. 1926.450, 1926.451, 1926.452, 1926.453, 1926.454
OSHA compliance of Terra Flex stair system (models L-400 and A-500). 1926.1052, 1926.1053, 1926.1050, 1926.502(h), 1926.502(j), 1926.1051(a)
Construction standards for equipment such as Shuttle Buggy. 1926.600, 1926.601, 1926.555, 1926.1050, 1926.1053, 1926.800, 1926.407
Acceptability of an engineered steel fire barrier to comply with separation/firewall requirements. 1926.350(a), 1926.350(a)(10)
Application of OSHA requirements to self-employed construction workers. 1975.3(d)
Applicable construction standards to hydraulic cranes and derricks. 1926.550, 1910.180, 1926.550(a)(17), 1926.550(a)(15)
Hazwoper training for security guards; documentation necessary when training varies. 1910.120(q)(6)
Needlestick Safety and Prevention Act amplifies the requirements to use safer needle devices. 1910.1030(d)(2)
Exemption from the requirement to wear hard hats for religious reasons. 1926.100, 1926.100(a)
Development of slip-resistance testing methods on structural steel. 1926.754(c)(3)
Backcut requirements for Humboldt cutting. 1910.266(h)(2)(vii)
Standards applicable to aerial lifts; acceptable uses of body belts as restraint systems and positioning devices. 1926.453(a), 1926.453(b)(2), 1926.500(b), 1926.502(d), 1926.502(e), 1926.453(b)(2)(i), 1926.453(b)(2)(ii), 1926.453(b)(2)(iii), 1926.453(b)(2)(iv), 1926.453(b)(2)(v), 1926.453(b)(2)(vi), 1926.453(b)(2)(vii), 1926.453(b)(2)(viii), 1926.453(b)(2)(ix), 1926.453(b)(2)(x), 1926.453(b)(2)(xi), 1926.453(b)(2)(xii)
Requirements applicable to the design, inspection, and testing of imported scaffolding. 1926.452(o), 1926.452(p), 1926.452(q), 1926.451(f)(3), 1926.450(a), 1926.450, 1926.451, 1926.452, 1926.453, 1926.454
OSHA's gravity-based penalty policy and consultation service. 1903.15(b), 1908.1
Application of 1926.800 to lone employees working underground in a tunnel or shaft connected to a tunnel. 1926.800, 1926.800(c), 1926.800(f)(5), 1926.800(a), 1926.800(g)(2), 1910.134, 1926.103, 1926.800(e), 1926.800(f)(1)
Fall protection requirements for workers engaged in "roof blocking." 1926.501(b)(1), 1926.501(b)(13), 1926.501(b), 1926.501, 1926.501(b)(10)
Use of aerial lifts to transport workers to elevated workstations; scissor lifts are not covered by the aerial lift provisions. 1926.453(b)(2), 1926.453(b)(2)(iii), 1926.453(b)(2)(v), 1926.501(b)(1), 1926.452(w), 1926.451, 1926.502(d), 1926.453
Application of CPL 2-1.29, Interim Inspection Procedures during Communication Tower Construction Activities. 1926.550(g)(2), 1926.753(a)(4), 1926.750, 1926.550(g)
Review of electrical schematic diagrams; OSHA does not approve equipment designs. 1910.399(a), 1910.304(f)(3)(i)