Clarification Regarding the Requirements of 29 CFR 1910.147
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.
November 24, 2025
Mr. Kevin C. Orcutt
Warhawk Safety Consultants, Inc.
675 Wellington Dr.
Union Grove, WI 53182
Dear Mr. Orcutt: