Letters of Interpretation | Occupational Safety and Health Administration

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
11/05/1999	Clarification of HIV and HBV research and clinical laboratories.	1910.1030(b), 1910.1030(e)
11/04/1999	PSM coverage of oil and gas production and separation facilities.	1910.119(a), 1926.64(a)
11/03/1999	Use of "generic" LOTO procedures in conjunction with "work authorization permits".	1910.147(c)(1), 1910.147(d)(3), 1903.14(f)
11/02/1999	Powered industrial truck requirements regarding "split-forking" and "bulldozing."	1910.178(o)(1), 1910.178(l)(3)(i)(M)
11/01/1999	Bloodborne Pathogens: Handwashing facilities must be readily accessible.	1910.1030(d)(2)(iii), 1910.1030(d)(2)(v), 1910.1030(d)(2)(vi)
11/01/1999	Location of employee's records who are not associated with fixed establishments.	1904.14
11/01/1999	HAZCOM: Clarification of "article" and "hazardous substance".	1910.1200(c), 1910.1200(d)(4)
11/01/1999	Recordability of injury/illness resulting solely from a physical defect.	1904.2
10/29/1999	Employers must ensure that post-exposure follow-up procedures are provided.	1910.1030(f)(3), 1910.1030(f)(5)
10/29/1999	Clarification of when injuries and illnesses are work-related and recordable.	1904.2
10/28/1999	Host employers may require site-specific forklift training of visiting workers	1910.178(l)
10/26/1999	Minimum approach distances when using insulating gloves and sleeves.	1910.269(l)(2)
10/22/1999	Fork inspection requirements for powered industrial trucks.	1910.178(a)(2), 1910.178(l), 1910.178(q)(7)
10/22/1999	Forklifts: free rigging requires manufacturer approval.	1910.178(a)(4)
10/21/1999	Employee hand placement on and around suspended crane loads.	1926.1425
10/21/1999	Earthmoving equipment is not covered by 1910.178; skid- steer equipment may be covered.	1910.178(a), 1910.178(l), 1926.602(d)
10/21/1999	Employees (daycare workers) required to provide first aid are covered by 1910.1030	1910.1030
10/20/1999	PRCS entry: the term "body" includes all extremities.	1910.146(b)
10/20/1999	Trench shields must be installed to prevent lateral movement in a collapse.	1926.652(g)(1)(ii)
10/20/1999	Using "stick-on" labels to meet the requirements of 1910.1200.	1910.1200(f)