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. This 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. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 21, 1992

Ms. Regina Keenan
Training Coordinator
Carpenter Health & Safety Fund of
North America United
Brotherhood of Carpenters
101 Constitution Avenue N.W.
Washington, D.C. 20001

Dear Ms. Keenan:

This is in response to your letter of April 8 requesting information about the Occupational Safety and Health Administration (OSHA) training requirements for the use of Level 1 lasers. I apologize for the delay in responding to your inquiry.

Although paragraph 29 CFR 1926.54(a) requires employees assigned to install, adjust, and operate laser equipment (including Level 1 type lasers) to be trained, there are no additional specific OSHA regulations that indicate what training is necessary. Consequently, the general safety training and education requirements of 29 CFR 1926.21(b) apply and those have been interpreted by OSHA to require at least the following:

1. The employer shall provide for the instruction of each laser equipment operator and instructor in accordance with the applicable manufacturer's recommendations. The instruction process shall inform the operator of various hazards associated with the use of the equipment and the necessary or recommended control measures for the elimination of hazards to personnel. In addition to information from the manufacturer, the American National Standard ANSI Z136.1-1986 could be reviewed for training information.

2. Instruction should be conducted by a qualified representative of the manufacturer, or by a knowledgeable individual designated by the employer.

It is always a good practice to maintain employee training documentation at the construction site so that the records are available for review by a compliance officer. If you have further questions, please do not hesitate to contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff at (202) 219-8136.


Roger A. Clark
Acting Director
Directorate of Compliance Programs