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
OSHA 300 Log requirements versus HIPAA privacy requirements. 1904 - Table of Contents, 1904.35(b)(2)(iv)
Tuberculosis and Respiratory Protection. 1910.134, 1910.134(c), 1910.134(e), 1910.134(f), 1910.134(k), 1910.134(m)
Powered Industrial Trucks: examination prior to being placed in service; evaluations conducted orally versus written; multi-level evaluations; seatbelt use. 1910.178, 1910.178(q)(7), 1910.178(q)(6), 1910.178(l)(1), 1910.178(l)(3)
Requirements for working clearances and spaces around electrical equipment, e.g., ladder cable trays. 1910.303(g), 1910.303(g)(2)(ii), 1910.303(h), 1910.303(h)(2)(ii)
Respiratory protection program requirements for M. tuberculosis based on risk assessments; applicability of the respirator standard to long-term healthcare facilities. 1910.134
Hazard Communication: classification of uninterruptible power source batteries and office chemicals as "consumer products." 1910.1200, 1910.1200(c)
Fall protection requirements for elevated platforms of powered industrial trucks; body belts versus harnesses 1910.178
Requirements in 1926 Subpart L "Scaffolds" regarding the use of plywood to make platform decking for scaffolds. 1926.450(b), 1926.451, 1926.451(a)(1), 1926.451(a)(6), 1926.451(b), 1926.451(f)
Automated External Defibrillator training is not specifically required by the Permit-Required Confined Space standard; AEDs are not required first aid supplies. 1910.146(k)(2)(iii), 1910.151(b)
Clarification of the Powered Industrial Truck (1910.178) standard's use of the terms "in need of repair," "defective," and "unsafe." 1910.178, 1910.178(p)(1), 1910.178(q)(1), 1910.178(p), 1910.178(q)
OSHA's guidelines are advisory, do not create new employer obligations, and are not basis for citations.
The meaning of standards can only be modified through the rulemaking process, not through a letter of interpretation. 1926.1053(b)(7)
OSHA jurisdiction over oil and gas pipelines may be preempted by DOT standards. 1926.651(b)(2), 1975.1
The construction fall protection standard specifies fall arrest system requirements, but no footwear requirements. 1926.501(b)(11), 1926.500(b), 1926.96
Steel erection columns must be anchored by 4 rods and meet 300-lb strength criteria. 1926.755(a)(1), 1926.755(a)(2), 1926.752(b)
Requirements for manufacturers, who are no longer in business or have discontinued a product line, to provide MSDSs and product information. 1910.1200, 1910.1200(g)(1)
Equipment reverse signal alarms must be audible above surrounding noise level. 1926.601(b)(4), 1926.601(b)(4)(i), 1926.601(b)(4)(ii), 1926.602(a)(9)(ii)
Fixed ladders must be retrofitted to meet 1910.27 design requirements; maximum horizontal spacing requirements for extensions. 1910.27, 1910.27(d)(1)(i), 1910.27(d)(1)(ii), 1910.27(d)(v)
The use of extension cord while working from scissor lift; requirement to secure or barricade a ladder. 1926.451, 1926.452(w), 1926.1053(b)(8)
Bloodborne Pathogens Standard application to bifurcated needles; acceptability and appropriateness of safety bifurcated needles. 1910.1030, 1910.1030(c)(1)(iv)(B), 1910.1030(c)(1)(v), 1910.1030(d)(2)(i)