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
Recordkeeping: count of lost workdays when worker not scheduled to work or is terminated. 1904.2, 1904.12
Recordkeeping: lost workdays that occur prior to diagnosis must be recorded. 1904.2, 1904.12
Clarification of requirements for daily disposal of combustible wastes. 1910.106(e)(9)(iii)
OSHA regulation of liquified paving asphalt; not covered by 1910.106. 1910.106
Scaffolds placed in service after January 1,2000 must meet new rail height requirements. 1926.451(g)(4)(ii)
Evaluation of a single-person, manually propelled, mobile work platform. 1926.452(w), 1926.450, 1926.451, 1926.454
Fall protection non-conforming guardrail criteria for application of a de minimis policy. 1926.500, 1926.501(b)(2)(ii), 1926.501(b)(4)(i), 1926.501(b)(4)(ii), 1926.501(b)(4)(iii), 1926.501(b)(10), 1926.502(b), 1926.501(b)(2), 1926.502(f)(2)
Pre-operation forklift examinations are not required to be written. 1910.178(q)(7)
Use of X-ray fluorescence (XRF) is not acceptable to determine employee lead exposures 1926.62(d)
Clarification of fixed stairs strength; minimum of 1,000 lbs. 1910.24(c)
Recordkeeping: several clarifications of first aid vs. medical treatment. 1904.2, 1904.12, 1952.4
Trainee signatures are not required to verify training; U.S. Postal Service is covered by the OSHAct. 1910.132
The BBP standard applicability to home health care service workers. 1910.1030
Application of 1910.1030 (HBV vaccination series) to police, firefighters, and accident investigators. 1910.1030(f)(1)(ii)(D), 1960.16, 1975.5
Recordkeeping: accommodation camps are ordinarily considered a "home away from home." 1904.2
Minimum width of exit routes; redesignation of 1910.1020. 1910.37, 1910.36(g)(2), 1910.36, 1910.36(b), 1910.24(d), 1910.1020
Leather gloves are considered personal protective equipment. 1910.132
Employee training for water rescue at an amusement park.
Injuries that occur during business travel are recordable. 1904.2
Energy control procedures must be developed unless eight conditions met. 1910.147(c)(4)(i), 1910.147(b)