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.

Filters


Date Title Standard Number
Clarification of OSHA denial of FirePASS's variance request and respiratory protection requirements in oxygen-deficient atmospheres. 1910.134, 1910.134(d)(2)(iii)
Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER. 1910.120, 1910.120(e), 1910.120(e)(2)(i), 1910.120(e)(3)(i), 1910.120(q), 1910.120(q)(6)(iii), 1910.120(q)(6)(iii)(D)
Placement of sharps containers and requirement to ensure they are maintained in an upright position. 1910.1030, 1910.1030(c), 1910.1030(d)(4)(iii)(A)(2)(ii)
Clarification of the requirement to provide accurate and current hazard information on an MSDS. 1910.1200, 1910.1200(g)(2)(xi)
Request to provide list of corrosive materials and concentrations requiring use of emergency eyewashes and showers. 1910.132(d), 1910.133(a)(1), 1910.151(c)(1), 1910.1200(c), 1910.1200(g), 1926.50(g)
Use of jack stands in the stabilization of semi-trailers. 1910.178, 1910.178(k)(3)
Whether a pH buffer solution can be used as a cleansing agent for employees who work with portland cement 1910.141(d)(2), 1910.141(d)(2)(i), 1910.141(d)(2)(ii), 1910.141(d)(2)(iii), 1910.141(d)(2)(iv), 1915.97(b), 1926.51(f)(1)
Requirements for spray booth when spraying water-based paint. 1910.94, 1910.94(c), 1910.94(c)(2), 1910.94(c)(8), 1910.107
Clarification of employer's obligation to include social security numbers on employee exposure records. 1910.1025, 1910.1025(d)(5), 1910.1025(n)(1)(i), 1910.1025(n)(1)(ii)(D), 1910.1026
Policy on posting of floor load capacity signs. 1910.22, 1910.22(d)
Tuberculosis and Respiratory Protection Enforcement 1910.134, 1910.134(f)(2)
Use of pole gaffs when working with thin-barked trees near telecommunication lines. 1910.268, 1910.268(a)(1), 1910.268(g)(3)(iv)(A)
Determining whether an aircraft fuel tank is considered a confined space. 1910.146, 1910 Subpart Z
Clarification of whether an employee can opt out of medical surveillance examinations under the HAZWOPER standard, 29 CFR 1910.120. 1910.120, 1910.120(f), 1910.120(q)(9), 1910.120(q)(9)(i)
Whether employees who are verifying that an electrical system is de-energized or are turning off circuit breakers are required to use personal protective equipment 1926.95(a), 1926.416(a), 1926.416(a)(1), 1926 Subpart K
Compliance with electric power generation transmission and distribution requirements for testing of fiberglass insulating tools. 1910.269, 1910.269(j)(1), 1910.269(j)(1)(iii), 1910.269(r)(1)(iv)
Whether employers may designate an outside consultant as the Chemical Hygiene Officer under 1910.1450. 1910.1450, 1910.1450(b)
Storage requirements for discarded filters/pads and for water-filled metal containers in 1910.107. 1910.107, 1910.107(b)(5)(ii)
Whether the material storage requirements in 1926.250(a)(1), (b)(6) and (b)(7) apply to stored and stacked brick and masonry blocks that remain completely secured as shipped (interlocked, banded, shrink-wrapped, or similarly bound for shipment) 1926.250, 1926.250(a)(1), 1926.250(b), 1926.250(b)(6), 1926.250(b)(7)
Whether shutting off the truck and disabling controls is a sufficient means of demonstrating that no employee would be endangered under 1910.269(p)(1)(iii). 1910.269, 1910.269(p)(1)(iii)