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
Pump jack scaffolds must be braced at their bottom. 1926.452(j)(2), 1926.450(b)
Application of the Confined Spaces Advisor to construction; personal fall arrest system requirements. 1926.21(b)(6)(i), 1926.353(b), 1926.502(d), 1926.651(g), 1926.800, 1926.956, 1910.146(a)
Guard requirements for concrete mixers with loading skips. 1926.300(b)(3), 1926.300(b)(4), 1926.702(b)
Hepatitis B vaccination requirements for employees providing first aid as a collateral duty. 1910.1030(f)(2), 1960 - Table of Contents
OSHA does not regulate design specifications for splicing plates on roof trusses.
Authorized employees may, but are not required to, verify energy isolation in group LO/TO. 1910.147(f)(3)
Recording injuries/illness of pool nurses (temporary employees);needlestick recordkeeping. 1904.2, 1910.1030(c)(1)(ii)(C), 1904.12(c)
Requirements to prevent trench collapse during sheet-pile operations. 1926.603(c)(3), 1926.652(b), 1926.651(j)
Clarification of when mechanical equipment can be used on sloped roofs. 1926.502(f)(1), 1926.502(f)(4), 1926.502(h)(2)
Use of compressed air above 30 p.s.i. for cleaning purposes;nonmetallic-sheathed cable for temporary wiring. 1926.302(b)(4), 1926.405(a)(2), 1926.405(a)(2)(ii)(B)
Responsibility for cleaning/preventing exposure to contaminated emergency medical equipment. 1910.1030, 1910.1030(d)(4)(i), 1910.1030(d)(4)(ii), 1910.1030(d)(4)(iv), 1910.1030(e)(2)(ii)(B)
Hearing protection and the responsibility for paying for the hearing protectors including replacement devices/parts. 1910.95, 1910.95(i)(1), 1910.132
Rollover protective structures are required for earthmoving "dumpers." 1926.602(a)(1), 1926.602(a)(6), 1926.1000
Applicability of bloodborne pathogens standard to athletic trainers; handling of contaminated laundry. 1910.1030, 1975.3(d)
Training obligations of temporary employment agencies and host employers. 1975.3
Applicability of PSM standard to on-site use of methane as fuel. 1910.119(a)(1), 1910.119(h)(3), 1926.64(a)(1), 1926.64(h)(3)
A five-gallon paint pail should not be used as a step stool.
A lock is considered a lockout device. 1910.147(b)
Batteries in electric powered industrial trucks must be secured horizontally and vertically. 1910.178(g)(5)
Surgical smoke is not covered by the Bloodborne Pathogens Standard. 1910.1030(b)