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
Work-related injuries and illnesses that occur in home-based worksites are recordable. 1904.2, 1904.12
Evaluation of proposed modifications to the Bureau of Prisons' Lockout/Tagout (LOTO) procedures. 1910.147, 1910.147(e)(3), 1910.333, 1910.333(a)(1), 1910.333(b)(2), 1910.333(b)(2)(v)(C)
Double-walled tanks do not reduce the minimum separation distances for flammable and combustible liquids. 1910.106(f)(3)(i)
"Approval" of flexible corrugated plastic covers and generic circuit breaker panel switch lockouts. 1910.305(b)(2), 1910.147(c)(5), 1910.303(g)(2)(ii)
All injuries/illnesses that result in days away from work are recordable. 1904.12(c), 1904.2(a)
Numerous injury and illness recordkeeping questions. 1904 - Table of Contents
PPE must be provided for serious sun exposure hazards. 1910.132(a)
Use of height adjustable beds help reduce back injuries during patient care.
Electric power tools: grounding, NRTL approval, and suitable circuit connection. 1926.404(b)(2), 1926.403(a), 1926.404(f)(7)(iv)
Clarification of requirements for 1000 gallon diesel storage tank. 1926.152, 1926.155(h)
Requirements for scaffold toprails and midrails;moving mobile scaffolds; outrigger frames. 1926.451(g), 1926.451(h), 1926.452(w)
Clarification of single and multiple crews for purposes of deenergizing lines. 1910.269(m)(3)(viii)
An attendant may participate in non-entry confined space rescue under certain conditions. 1910.146(k), 1910.146(i)
Meaning of January 1, 2000 "placed in service" date for scaffolds. 1926.451(g)(4)(ii)
Clarification of residential construction's use of slide guards and other fall protection 1926.501(b)(13), 1926.502(k)
Recordkeeping: count of lost workdays when worker not scheduled to work or is terminated. 1904.2, 1904.12
Recordkeeping: lost workdays that occur prior to diagnosis must be recorded. 1904.2, 1904.12
Recordkeeping: clarifications of second visits for recordability. 1904.2, 1904.12(e)
Clarification of requirements for daily disposal of combustible wastes. 1910.106(e)(9)(iii)
OSHA regulation of liquified paving asphalt; not covered by 1910.106. 1910.106