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.

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How to Request a Letter of Interpretation

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Date Title Standard Number
Clarification regarding the applicability of PSM to chemical distributors that merely store, transfer, and/or non mechanically blend flammable liquids. 1910.119
OSHA PPE standard requirements for hazard assessment and employee training and the OSHA HAZWOPER standard requirements. 1910.120, 1910.132
Permanent variance from the labels and signs requirements of the Bloodborne Pathogens standard. 1910.1030
The application of the OSHA HAZWOPER standard to employers of transfer facilities. 1910.38, 1910.120, 1910.120(a)(2)(iii), 1910.120(p), 1910.120(p)(8), 1910.120(p)(1)
OSHA policy regarding the use of rebar assemblies as ladders. 1926.501
Fall protection requirements where employees are required or permitted to cross over excavations. 1926.651, 1926.651(l), 1926.651(l)(1)
Guidelines for the Enforcement of the Apparel Standard 1910.269
The interpretation of the medical examinations and consultations for employees who are hired for areas that have ethylene oxide 1910.1047
The proper recording of illness cases on the OSHA Log and Summary of Occupational Injuries and Illnesses. 1904 - Table of Contents
Letter requesting a compliance determination of control device system used primarily in paint spray booth applications. 1910.107
The classification of medical treatment for OSHA injury and illness recordkeeping purposes. 1904 - Table of Contents
A qualified employee wearing a short sleeve shirt when working on or nearby energized electric power line or equipment and subject to potential exposure to an electric arc. 1910.269
Interpretation on the control of hazardous energy (lockout/tagout) standard. 1910.147
Clarification of the electric power generation, transmission, and distribution standard. 1910.269
Heat-treating process (using methanol) and the applicability of the Process Safety Management of Highly Hazardous Chemicals Standard. 1910.119
Interpretation of the Electric Power Generation, Transmission, and Distribution Standard. 1910.269
OSHA's approval of the Zurich Hazard Analysis, as an appropriate method for conductiong the process hazard analysis which is required by 1910.119. 1910.119
Clarification of the Electric Power Generation, Transmission, and Distribution Standard with regard to recreational tree trimmers. 1910.269
Fall protection for an extendable gangway. 1910.23(c)
Clarification of training requirements under 1910.151, (Medical Services and First Aid). 1910.151