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.

Date	Title	Standard Number
11/05/2004	Powered Industrial Truck 1910.178(l) training requirements applicable to construction; training for skid-steer loader operators.	1910.178, 1910.178(a), 1910.178(l), 1926.20(b)(4), 1926.21(b)(2), 1926.602(a), 1926.602(d)
11/04/2004	Evaluation of what is considered a safe speed to operate powered industrial trucks (forklifts)	1910.178(n)(8), 1910.178(n)(15)
11/04/2004	OSHA does not enforce NFPA 70E, although it may use NFPA 70E to support citations relating to certain OSHA standards.	1910.335
10/28/2004	Requirements for providing medical evaluations prior to wearing respiratory protection for training exercises.	1910.134, 1910.134(e)
10/28/2004	Top rail and handrail requirements for stairrail systems under the construction standards.	1910.23(e)(1), 1910.24(h), 1926.1052, 1926.1052(c)(6), 1926.1052(c)(7), 1926.1052(c)
10/21/2004	Respiratory protection medical evaluations: additional evaluations; use of employee's physician; testing; medical removal; and confidentiality.	1910.134, 1910.134(c), 1910.134(e)(5)
10/20/2004	LOTO: minor servicing exemption and the use of a lockable on/off switch as an alternate measure to provide effective protection.	1910.147, 1910.147(a)(2)(ii)
10/18/2004	Requirements for fit testing employees before fire brigade training exercises.	1910.134, 1910.134(f)
10/12/2004	Evaluation of using a curbing system for a land crane on a barge to meet the requirements to positively secure the crane to the barge.	1926.550(f), 1926.550(f)(1)(iv)
10/06/2004	Loads must be attached to the block hook by a sling or other approved device and may not be attached directly to the running rope.	1910.179, 1910.179(n)(2)(i), 1910.179(n)(2)(ii)
10/05/2004	Ladder safety requirements for towers more than 20 feet in length: sliding fall protection devices, safety cages/wells, landing platform intervals.	1910.27, 1910.27(d)(5), 1910.27(d)(1)(ii), 1910.27(d)(2), 1910.23
10/05/2004	Grounding requirements for aerial lifts (bucket trucks) under the General Industry 1910.269 and Construction 1926.952 standards.	1910.269, 1910.269(n)(6), 1910.269(n)(7), 1910.269(l)(2), 1926.950(c), 1926.952(b)(2), 1926.954(e)(1), 1926.954(e)(2)
09/30/2004	Clarification if a depression constitutes a hole or unprotected side/edge and associated fall protection requirements.	1926.500(b), 1926.501(b)(1), 1926.501(b)(4)(i), 1926.501(b)(4)(ii), 1926.502(b)
09/30/2004	Permissibility of using average excavation depth to determine protective system requirements for the excavation.	1926.650, 1926.652(a)(1)(ii), 1926.652(a)(1), 1926.652(b), 1926.652(c)
09/27/2004	Alternatives to common back-up alarms on construction motor vehicles; use of other effective technology or observers/signal persons.	1926.601, 1926.601(b), 1926.601(b)(4), 1926.601(b)(4)(i), 1926.601(b)(4)(ii), 1926.602, 1926.602(a), 1926.602(a)(9), 1926.602(a)(9)(ii)
09/27/2004	OSHA's web site postings of settlement agreements, citations, and proposed penalties for inspections are public information subject to the disclosure pursuant to the FOIA.	2200.100(c)
09/24/2004	Applicable standards for telecommunications non-industry specific operations, e.g., retail, call center, warehouse, and administrative locations.	1910.268, 1910.268(a), 1910 - Table of Contents, 1910.5(c), 1910.268(a)(3), 1910.268(g)(1), 1910.268(n)(7), 1910.268(n)(8)
09/20/2004	Regulations concerning the size and use of safety traffic cones in General Industry.	1910.145
09/17/2004	Bloodborne Pathogens Standard as it relates to contaminated laundry, sharps containers, and the Hepatitis B vaccine in fitness centers.	1910.1030, 1910.1030(a), 1910.1030(b), 1910.1030(c)(2), 1910.1030(d)(4)(iv)(A), 1910.1030(d)(4)(iv)(A)(1)
09/17/2004	Protection of employees from exposure to live electrical parts with plastic switch plates/receptacle cover and non-conductive screws.	1926.405(j)(1)(i), 1926.416(a)(1), 1926.404(f)(7)(i)

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