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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Date Title Standard Number
Use of cab shields on haulage vehicles with 4 ft separation between cab and dump truck body. 1926.601(b)(6)
OSHA coverage does not extend to home-based care for the elderly. 1975.6
Requirements for scaffold grade lumber; qualifications of qualified/competent persons for grading scaffold lumber. 1926.451(b), 1926.452(e), 1926.452(p)(4), 1926.450(b), 1926 Subpart L App A
Use of engineering and work practice controls during pouring of blood or OPIM. 1910.1030(d)(2)(i), 1910.1030(c)(1)(iv), 1910.1030(d)(4)(iii)
OSHA's fixed ladder requirements do not apply to vehicle-mounted fixed ladders. 1926.1053, 1926.1050(b)
Acceptability of Task-Based Noise Exposure Assessment Modeling (T-BEAM). 1910.95(d)(1)(i), 1910.95(d)(1)(ii)
Determination of safety for existing process equipment is required prior to start-up. 1910.119(d)(3)(iii)
Retailer exemption from the PSM standard for anhydrous ammonia dealers. 1910.119(a)(2)(i)
Employers must provide exposed employees access to their medical and exposure records. 1910.1020(d), 1910.1020(e)
Hazards of Inipol EAP22 used during cleanup of oil spills. 1910.1200
Application of 1926.451(b)(3)(ii) to "Drivit" (synthetic stucco) systems. 1926.451(b)(3)(ii)
Hoists for suspension scaffolds must be tested by a qualified testing laboratory. 1926.451, 1926.449
Fall protection: determination of roof width on irregular shaped roofs. 1926.501(b)(10), 1926.502(h)
Acceptable use of load-limiting clutches as upper and/or lower limit devices. 1910.179
Labeling requirements under the HAZCOM and Laboratory standards;use of safe needle devices. 1910.1200(f), 1910.1450(h)(1)(i), 1910.1030(d)(2)(i)
PR 600 Mobile Fall Protection System. 1926.502
Roofing material vendors must provide employee fall protection. 1926.501
Ergonomics standard requirements concerning initial program evaluation. 1910.900(c)
Engineering controls must be used to prevent needlesticks where feasible. 1910.1030(d)(2)(i), 1910.1030(d)(2)(viii)
Thomas' MAPP gas glass mold heat processes fall within the PSM hydrocarbon fuels exemption. 1910.119(a)(1)(ii)(A)