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
Use of X-ray fluorescence (XRF) is not acceptable to determine employee lead exposures 1926.62(d)
Recordkeeping: several clarifications of first aid vs. medical treatment. 1904.2, 1904.12, 1952.4
The BBP standard applicability to home health care service workers. 1910.1030
Trainee signatures are not required to verify training; U.S. Postal Service is covered by the OSHAct. 1910.132
Application of 1910.1030 (HBV vaccination series) to police, firefighters, and accident investigators. 1910.1030(f)(1)(ii)(D), 1960.16, 1975.5
Recordkeeping: accommodation camps are ordinarily considered a "home away from home." 1904.2
Minimum width of exit routes; redesignation of 1910.1020. 1910.37, 1910.36(g)(2), 1910.36, 1910.36(b), 1910.24(d), 1910.1020
Employee training for water rescue at an amusement park.
Leather gloves are considered personal protective equipment. 1910.132
Injuries that occur during business travel are recordable. 1904.2
OSHA will not enforce the PSM standard at oil and gas production facilities. 1910.119(a)
Energy control procedures must be developed unless eight conditions met. 1910.147(c)(4)(i), 1910.147(b)
Applicability of Marine Terminal and Longshoring standards to cargo handling. 1918.1(a), 1917.1(a)
Use of electronic signature pad to record signatures for training certification. 1910 - Table of Contents, 1915 - Table of Contents, 1917 - Table of Contents, 1918 - Table of Contents, 1926 - Table of Contents, 1928 - Table of Contents, 1960 - Table of Contents
Competency of powered industrial truck trainers; training must be truck- and site-specific. 1910.178(l)(2)(ii), 1910.178(l)(3)(i), 1910.178(l)(3)(ii)
Powered industrial truck training for employees working at another employer's worksite. 1910.178(l)
Abbrasive blast cleaning nozzles must be equipped with a "dead-man" control. 1910.244(b)
Training required for commercial divers. 1910.410
Compliance with PSM and ANSI/ISA-S84.01 for safety instrumented systems 1910.119(d)(3), 1910.119(f)(1)(iv), 1910.119(j)
Lockout/tagout: preferred means of energy isolation; non cord-and-plug powered equipment. 1910.147(a)(2)(iii)(A), 1910.147(c)(3), 1910.269(m), 1910.333(b)