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
A five-gallon paint pail should not be used as a step stool.
Batteries in electric powered industrial trucks must be secured horizontally and vertically. 1910.178(g)(5)
A lock is considered a lockout device. 1910.147(b)
Surgical smoke is not covered by the Bloodborne Pathogens Standard. 1910.1030(b)
Employees engaged in formwork over 6 feet high must have fall protection. 1926.501(b)(1), 1926.501(b)(2), 1926.501(b)(5), 1926.451(g)
Clips used for wire rope guardrails; required fall protection in hoist area. 1926.501, 1926.502
Clarification of OSHA policy regarding the use of scaffold stairs for access to a multi-story structure. 1926.451, 1926.1051
Employees must be kept clear of suspended loads, including multiple lift loads. 1926.550(a), 1926.753(c)
Noise exposure measurement records must be retained for 2 years. 1910.95(m)(3)(i), 1910.1020(d)(1)
Fall protection for various lift-devices; restraint, positioning, fall arrest and rescue requirements; maintenance vs. construction examples. 1926.451(g)(1)(vii), 1926.451(g)(4), 1926.453(b)(2)(v), 1926.500, 1926.502(d), 1926.502(d)(20)
Clarification of the terms "hole" versus "unprotected sides or edges." 1926.500, 1926.501(b)(1), 1926.501(b)(4), 1926.32(f)
Fall protection requirements for residential construction (STD 3-0.1A). 1926.500, 1926.501, 1926.502, 1926.503
Anchoring 2-point suspension scaffolds;criteria for testing anchorages. 1910.66, 1910.28(g)(11), 1926.451(d)(18)
Trench shield must extend 18" above excavation walls when below grade. 1926.652(b), 1926.650, 1926.651(j)(2)
Alloy steel chain slings must not be loaded beyond working load limit. 1926.251(b)(4), 1926.251(a)(2), 1926.550(a)(19)
Tie, guy, and bracing requirements for scaffold systems. 1926.451(a)(1), 1926.451(a)(6), 1926.451(c)(1)(ii), 1926.451(c)(1)(iii), 1926.451(c)(3)
Acceptable use of warning lines as fall protection for roofers and other trades. 1926.501(b)(10), 1926.501(b)(2), 1926.501(b)(12), 1926.501(b)(13), 1926.502(b)
Scissor lifts are not aerial lifts, are considered scaffolds. 1926.451, 1926.453
Foundation requirements for scaffolds; competent person qualifications for assessing foundations. 1926.451(c)(1)(iii), 1926.451(c)(2), 1926.451(c)(2)(i), 1926.451(f)(3), 1926.451(f)(7), 1926.450
Recordability of treatment for hydrofluoric acid burns. 1904.12(c), 1904.12(e)