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
Substituting portable toilets for water closets may be a de minimis violation. 1910.141(a)(1), 1910.141(c)(1)(i), 1910.141(d)
OSHA's position on the risk associated with asbestos exposure at the current PEL. 1910.1000(c), 1926.1101(c)
Vehicle-mounted elevating and rotating work platforms standard. 1910.67
Respirators for silica dust must be selected based on exposure levels. 1910.134(a)(1), 1910.134(a)(2)
Maintenance vs. construction; working from fixed ladders. 1910.12, 1926.1053(a)(18), 1926.1053(a)(19), 1926.1053(b)(4)
PSM applicability to a 50% Solution of Hydroxylamine. 1910.119(a)
Clarification of under voltage protection on metal-working equipment and emergency stop devices. 1910.216(b), 1910.303(b)(1)
Steel erection: applicability to metal roof systems and fall protection. 1926.750, 1926.105(a)
Clarification of 1910.269 as applied to line-clearance tree-trimming operations 1910.269(a)(1)(i)(E), 1910.269(a)(2)(ii), 1910.269(r)
Clarification of the requirement for an attendant during transfer of anhydrous ammonia. 1910.111(b)(12)(ii)
Chemical suppliers must ensure downstream flow of hazard information (MSDSs). 1910.1200(g)
Storage of propane and ether gas cylinders with flammable materials is not allowed. 1910.101(b)
Employers must record social security numbers in asbestos exposure monitoring records. 1926.1101(n)(2)(ii)(F), 1910.1001(m)(1)(ii)(F)
Employer's obligation to maintain and transfer medical records after the retainment period has passed. 1910.1020(c), 1910.1020(d), 1910.1020(h)(3)
NIOSH-approved abrasive-blasting respirators include other than "continuous flow air-line respirators." 1910.94(a)(1)(ii), 1910.94(a)(5)(i), 1926.57(f)(1)(ii), 1926.57(f)(5)(i)
OSHA guidelines for First Aid training recommend CPR training as an element. 1910.151, 1910.151(b)
Frequency of fit-testing for respirators to protect against M. tuberculosis exposure. 1910.139(e)(5)(i)
Vessel Safety - OSHA or U.S. Coast Guard. 1919.1
Refresher training requirements for operators of different types of trucks. 1910.178(l)
Preemption of respiratory protection standard by DOT's Office of Pipeline Safety regulations. 1910.134