OSHA Issues Letters of Interpretation
On December 10, OSHA announced that it has issued seven letters of interpretation to ensure the consistent and transparent application of federal workplace safety and health standards.
OSHA’s letters of interpretation provide official explanations of the agency’s requirements and how they apply to specific workplace situations and hazardous conditions posed by employers, employees, or other parties.
“From construction to engineering, OSHA is providing decisive guidance after gathering feedback from employers, demonstrating our opinion letter program has already been effective,” said Deputy Labor Secretary Keith Sonderling, in a statement. “This effort is a key component of the Trump Administration’s comprehensive strategy to educate the public and empower employers to keep their workers safe.”
Letters of interpretation issued this year address the following situations:
- Permit Required Confined Space: Whether the confined space standard requires employers to drain water from pipes before entering for repairs, even when a hazard assessment shows no risk of rupture or leaks.
- Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502: The enforcement status of OSHA’s COVID-19 reporting and recordkeeping requirements.
- Requirements of Powered Industrial Truck Training Program Implementation: Whether an employee can demonstrate competence and knowledge in operating power industrial trucks via a live-streamed session.
- Software used to generate equivalent OSHA Forms 300 and 300A: If companies are permitted to use their own software-generated documents to replace OSHA Form 300 and Form 300A for recordkeeping.
- Engineering controls under the Benzene and 1,3-Butadiene standards: Whether installing bellow valves, leak-proof, or double-seal valves qualifies as engineering controls.
- Audiometric testing of a worker who may have a cochlear implant: How audiometric testing applies to workers using cochlear implants.
- Stair Angle and Tread Depth Requirements: Whether stair and tread angles of specific dimensions comply with OSHA’s standard on stairways.
In June, Deputy Secretary of Labor Keith Sonderling announced the launch of the department's opinion letter program. Visit OSHA’s Letters of Interpretation page to review previous guidance and submit new requests.