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 http://www.osha.gov.

June 13, 1994

Mr. David Williams
Laser Technology, Inc.
7070 S. Tucson Way
Englewood, Colorado 80112

Dear Mr. Williams:

This is in response to your April 29 letter requesting clarification of the Occupational Safety and Health Administration (OSHA) standard addressing the use of lasers (29 CFR 1926.54(j)).

The term "direct staring" as used in paragraph 1926.54(j)(1) applies where an employee is required to or is likely to look directly into the beam, towards the source, in order to perform required work. The term "incidental observing" (1926.54(j)(2)) applies to exposure to an employee where looking directly into the laser is not required and is unlikely to occur in the performance of required work.

If we can be of any further assistance, please contact me or Mr. Dale R. Cavanaugh of my staff at (202) 219-8136.


Roy F. Gurnham, P.E., J.D.
Office of construction and
Maritime Compliance Assistance