Standard Interpretations - Publication Date | Occupational Safety and Health Administration

Standard Interpretations

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.

December

12/30/1991 - Medical surveillance of HAZWOPER and employer responsibility to employees. - [1910.120]
12/30/1991 - OSHA's jurisdiction over volunteer fire fighters. - [1910.120]
12/30/1991 - Training and HAZWOPER. - [1910.120; 1910.120(q)(1); 1910.120(q)(6)(ii); 1910.120(q)(6)(iii); 1910.38]
12/27/1991 - Use of general protective equipment and tools by employees when working near exposed energized conductors or circuit parts in the workplace - [1910.137; 1910.335; 1910.399]
12/24/1991 - Hazwoper minimum training for an On Scene Incident Commander. - [1910.120]
12/24/1991 - Mechanical power press requirements and platen presses. - [1910.217]
12/18/1991 - Fixed ladders in outdoor advertising. - [1905]
12/18/1991 - Hazwoper EPA and OSHA jurisdictional issues. - [1910.120]
12/16/1991 - Changing tines/capacity of powered industrial trucks. - [1910.178]
12/16/1991 - Washington's Response to Federal Program Change (CPL 2-2.51) - [1910.120]
12/12/1991 - Employees who become ill or injured on the job. - [1910.151]
12/10/1991 - Sharp knives and utensils in the workplace - [1910.132]
12/10/1991 - Underground storage tanks and 1910.120. - [1910.120]
12/06/1991 - Geographic definitions, multi-functional setting; refresher training. - [1910.120]
12/06/1991 - Use of crane or derrick suspended personnel platforms accessing a worksite. - [1926.32]
12/06/1991 - Use of ladders positioned against columns - [1926.1053(b)]
12/06/1991 - When a lifesaving skiff is to be considered as being "immediately available" - [1926.106]
12/05/1991 - Fireworks manufacturing and OSHA jurisdiction. - [1910.109]
12/05/1991 - New manlift installations. - [1910.68(b)(3)]
12/04/1991 - Training requirements of HAZWOPER. - [1910.120; 1910.120(e); 1910.120(e)(6)]
12/03/1991 - Powered Platform Installations for Building Maintenance - [1910.66]
12/02/1991 - Hazwoper training in hospitals. - [1910.120; 1910.120(q); 1910.1200; 1910.1047; 1910.1047(h); 1910.134; 1910.132]
12/02/1991 - OSHA Requirements Addressing Fall Protection Equipment - [1926.251]
12/02/1991 - Standards addressing excavations - [1910.120; 1926.652]
12/02/1991 - Use of protective helmets in construction - [1926.100(a); 1926.451(h)(1)]
12/02/1991 - Ventilation of industrial plants involved in flammable or combustible liquid operations. - [1910.106]
12/01/1991 - Ground continuity monitoring devices. - [1926.404]

November

11/25/1991 - Lift-slab Bridge Construction - [1926.703; 1926.704; 1926.705]
11/22/1991 - Aerial apparatus and ground ladders. - [1910.7]
11/22/1991 - Holding & Hoisting Brakes on Hydraulic Cranes - [1926.550]
11/21/1991 - The wearing of leather shoes rather than leather sneakers or deck shoes while operating vehicles. - [1910.132; 1910.136]
11/20/1991 - Occupational protective footwear for molten metal workers in the foundry industry. - [1910.132; 1910.136]
11/19/1991 - HAZWOPER applications. - [1910.120; 1910.120(a); 1910.120(d); 1910.120(e); 1910.120(e)(3)(ii)]
11/19/1991 - Requirement for Air Sampling in trenches. - [1926.651]
11/13/1991 - Proper wiring of a new overhead crane. - [1910.303]
11/08/1991 - Emergency situations that fall under Hazwoper. - [1910.120]
11/07/1991 - Concerning power press brake operations. - [1910.212]
11/07/1991 - Definition of "actual field experience" in Hazwoper. - [1910.120]
11/07/1991 - Design and use of trench boxes - [1926.652(g)(1)(iv)]
11/06/1991 - OSHA citations issued against Phillips 66 Company. - [2200.100]
11/05/1991 - Rollover Protective Structures (ROPS) used on agricultural wheeled tractors. - [1928.51]
11/05/1991 - Safety of employees in the workplace where portable generators are used as power sources. - [1910.302]
11/05/1991 - Yellow shall be the basic color for designation caution. - [1910.144]
11/01/1991 - Hearing report on OSHA reform.

October

10/31/1991 - Field Sanitation Standard. - [1928.110]
10/31/1991 - The terminology "making contact with the interior leg casing" in CPL 02-01-004 and grain handling facilities with less than one million bushels permanent storage capacity - [1910.272(p)(4)(ii)]
10/29/1991 - Noise and potential hazard of backup alarms on equipment at construction sites. - [1926.601(b)(4); 1926.602(a)(9)]
10/29/1991 - Stacking trench boxes in trenches. - [1926.650]
10/25/1991 - Differences between the various standards for Rollover Protective Structures used on agricultural wheeled tractors. - [1928.51(b)(1); 1926.1002(a)(5); 1926.1002(j)(1)]
10/22/1991 - The role of self-audits in safety and health programs - [1926.20(b)(2)]
10/16/1991 - Ergonomics in the Baking Industry.
10/16/1991 - Hazard Determinations under the HCS for Sodium Hypochlorite. - [1910.1200(d); 1910.1200(g)(2)]
10/11/1991 - Application of 1910.120 to home heating oil. - [1910.120; 1910.120(q)(6); 1910.120(q)(6)(ii); 1910.120(q)(6)(iii)]
10/08/1991 - Application of bridge brakes. - [1910.179]
10/08/1991 - Grain handling facilities. - [1910.272]
10/08/1991 - Over-the-road vehicle operator required response to a large release. - [1910.120; 1910.120(q); 1910.120(q)(1); 1910.38]
10/08/1991 - The use of Maxon-CS-0520-HD VHF transceivers. - [1910.399]
10/02/1991 - Training requirements for firefighters. - [1910.120; 1910.120(q)(6)(ii); 1910.120(q)(6)]
10/01/1991 - Approval of Portable Generators by a qualified testing laboratory. - [1926.403; 1926.404]
10/01/1991 - Classification and subsequent designs may be used if they have been approved by a registered professional engineer. - [1926.650; 1926.652]
10/01/1991 - End dump trucks on jobsites or public highways - [1926.601; 1926.601(b)(11)]
10/01/1991 - Force factor for fall arrest systems - [1910.66]
10/01/1991 - Manufacturer's Tabulated Data in the design and application of trench safety systems. - [1926.650]
10/01/1991 - Stairways used in construction. - [1926.1052; 1926.500]

September

09/25/1991 - Enforcement jurisdiction at IMC Fertilizer, Inc. - [1975.1]
09/25/1991 - Labeling Requirements for Crystalline Silica Products. - [1910.1200]
09/23/1991 - Worker Exposures to Volatile Amines - [1910.1200]
09/20/1991 - Operations level personnel training. - [1910.120]
09/12/1991 - Ability to reconcile the Occupational Safety and Health Administration's meatpacking guidelines. - [1975.1]
09/12/1991 - Electrical interface units used to connect nurse call systems with pocket page transmitters and other ancillary equipment. - [1910.303]
09/12/1991 - Machine guarding for the food processing industry. - [1910.212; 1910.219]
09/09/1991 - Requirement to develop MSDSs for pharmaceutical products and controlled substances - [1910.1200]
09/09/1991 - The storage of flammable and/or combustible materials in fiberglass reinforced plastic. - [1910.106]
09/06/1991 - Hepatitis B vaccination availability for health care workers - [1975.3]

August

08/30/1991 - Placement of vertical hydraulic shoring members; Bending strength of plywood; use of non-structural sheeting. - [1926 Subpart P]
08/28/1991 - NIOSH 582 training requirements relating to asbestos analysis slides - [1910.1001; 1926.58]
08/28/1991 - Reporting limits for Asbestos air concentrations. - [1910.1001; 1926.1101; 1915.1001]
08/28/1991 - Testing of Nucleopore and Millipore cassettes. - [1910.1001; 1926.1101]
08/27/1991 - OSHA's Hazardous Waste Operations and Emergency Response. - [1910.120; 1910.120(a)(1); 1910.120(q)(1); 1910.38; 1910.120(q)]
08/26/1991 - Concern for seasonal employees who are exposed in the fields to pesticides which are harmful to their health. - [1975.1]
08/26/1991 - Requirements that apply to the storage and handling of combustible liquids containing PCBs. - [1910.106]
08/20/1991 - On scene incident commander for Hazwoper standard. - [1910.120]
08/20/1991 - Training requirements of Hazwoper for various functions. - [1910.120; 1910.120(e); 1910.120(p); 1910.120(q); 1910.120(q)(11)(i); 1910.120(q)(11)(ii); 1910.120(e)(9); 1910.120(f); 1910.120(f)(3); 1910.38; 1910.134; 1910.1200]
08/19/1991 - Academic training considered as equivalently trained for Hazwoper. - [1910.120; 1910.120(e)(9); 1910.120(e)(2); 1910.120(b)(4)(ii)]
08/15/1991 - Applicability of the requirements of the Hazard Communication Standard to rubber dust byproduct sold by tire recapping company. - [1910.1200]
08/15/1991 - Decision or policy statement regarding the obligations and responsibilities of the employee leasing industry with respect to compliance with the Occupational Safety and Health Act. - [1910.1200; 1910.1030; 1910.178(l)]
08/15/1991 - Employees with previous experience and training in the removal of underground storage tanks. - [1910.120]
08/15/1991 - Hazard Communication and Consumer Products. - [1910.1200]
08/15/1991 - Used Tire Recyclers. - [1910.1200]
08/06/1991 - Actively involved; generators; CERCLA 101(33) substances. - [1910.120]
08/06/1991 - The flash point of Bio T products. - [1910.106]
08/05/1991 - Motor starter circuits and energy isolation devices - [1910.147]
08/02/1991 - The working environment of railroad train operating employees. - [1975.1]

July

07/30/1991 - Determination as to whether ConVault aboveground tanks are required to be diked to comply with the 1910.106(b)(2)(vii) standard on storage of flammable liquids. - [1910.106]
07/29/1991 - Characteristics of the Quick-Link device for the replacement of tire chain links. - [1910.212(a)]
07/29/1991 - Committing a de minimis violation when using an insert earphone designated as ER-3A. - [1910.95]
07/29/1991 - Grain Handling Facilities Standard. - [1910.272]
07/25/1991 - Labeling Provisions of the Hazard Communication Standard - [1910.1200(f)(6)]
07/25/1991 - The term "wheel chocks" and whether the employment of one chock would satisfy the requirements of the Occupational Safety and Health Administration. - [1910.178; 1910.178(k)(1)]
07/17/1991 - 1910.120 Application to Petroleum Product Spills or Releases Subject to State Codes - [1910.120]
07/17/1991 - Advance First-aid Requirements of 1910.120 - [1910.120(q)(3)(vi)]
07/16/1991 - OSHA compliance with Axe heads. - [1910.266]
07/12/1991 - Fall Protection while climbing and working on a steel lattice structure resembling a communication tower. - [1926.501]
07/11/1991 - Clearance of EEOC Policy Guidance on the Supreme Court Decision in the Johnson Controls, Inc. case.
07/11/1991 - Manufacturer Supplying Halon 1301 Systems for Fire and Explosion Suppression. - [1910.162; 1910.272]
07/10/1991 - Concrete and Masonry Construction standards and masonry walls. - [1926.706]
07/09/1991 - An explanation of the hazard it is designed to control. - [1910.107(b)(6)]
07/09/1991 - Requirements for guarding points of operation and belts on heavy duty sewing machines - [1910.212(a)(1); 1910.219]
07/08/1991 - Protection of flexible cords when hung in tunnel shafts. - [1926.405(a)(2)(ii)(I); 1926.800(s)(1)]
07/08/1991 - Protective Clothing for Firefighters - [1910.120; 1910.156]
07/02/1991 - Actual live fire not necessary in "hands on" practice training - [1910.155(c)(41)]
07/02/1991 - Standard for medical services and first aid - [1910.151]
07/01/1991 - Post Emergency Response Training Requirements - [1910.120]

June

06/26/1991 - Employee evacuation in the event of imminent Natural Phenomenon. - [1910.38; 1910.120; 1910.120(a)(1)(v); 1910.120(q)(1); 1910.120(q)(6)]
06/25/1991 - Cost of training is the employer's responsibility. - [1910.120; 1910.120(e)(6)]
06/21/1991 - All mobile housing units without exception, must comply with the general provisions for 1910.142. - [1910.142(b)(9)]
06/20/1991 - Safety and health protection for city government. - [1975.3]
06/18/1991 - Lead-based paint removal technology - [1910.1025; 1926.62]
06/17/1991 - Fires involving spills or releases of hazardous substances - [1910.120]
06/17/1991 - Minimum number of hours required for awareness level for police officers - [1910.120]
06/14/1991 - Boilermakers rebuilding an incinerator in a clean area at a Superfund site - [1910.120; 1926.21]
06/14/1991 - Maintaining Medical Records for Employees Subject to Medical Surveillance. - [1910.120; 1910.1020; 1926.1101]
06/14/1991 - New electrical standards relating to sugar beet plant and sawmill - [1910.331(c)(1)]
06/14/1991 - Requirements for backrest extensions and overhead guards for powered industrial trucks. - [1910.178]
06/14/1991 - Training requirements for emergency medical service personnel. - [1910.120]
06/12/1991 - Certifying employees as equivalently trained in hazardous waste operations - [1910.120(e)(9)]
06/12/1991 - Emergency response procedures for radioactive materials - [1910.120; 1910.120(q)]
06/11/1991 - The Hazard Communications Standard as it applies to employees who prepare and administer drugs/medications - [1910.1200]
06/10/1991 - Hazard communication in construction - general contractor responsibilities. - [1910.1200]
06/10/1991 - Training required for clean-up of hazardous waste and hazardous substances - [1910.120; 1910.1200]
06/07/1991 - Obligations contractors have, and if contractors and loggers, the latter as an employer, share responsibility for safety conditions in the forest. - [1910.266; 1910.266(h)(2)(ii)]
06/07/1991 - Requirements for training in hazardous waste for DOE personnel - [1910.120]
06/07/1991 - Training requirements for drivers hauling hazardous waste - [1910.120; 1910.120(e); 1910.120(e)(1); 1910.120(e)(2); 1910.120(e)(3); 1910.120(e)(4); 1910.120(e)(9)]
06/05/1991 - Error corrected in response of Sept. 4, 1990 concerning fire hazard associated with TCE - [1910.120]
06/05/1991 - Testing of type C soil is not necessary if employees are adequately protected. - [1926.650; 1926.652]
06/04/1991 - Interpretation of 1910.147, related to floating fish processors. - [1910.147]
06/04/1991 - Securing a personal fall arrest lanyard to a portable hook ladder as a safety measure - [1910]
06/04/1991 - Training required for emergency response at industrial facilities - [1910.120; 1910.134]

May

05/30/1991 - Grain elevator inspection activities - [1910.272]
05/23/1991 - OSHA's Hazard Communication Standard as it applies to the janitorial service industry. - [1910.1200]
05/15/1991 - Eight hours refresher training per year required specific to job responsibilities at a TSDF. - [1910.120]
05/15/1991 - Outer Shipping Container Labeling - [1910.1200]
05/15/1991 - The health and safety of employees who work in a State building housing the justice of Peace Courts and which is infested with termites. - [1975.3(d)]
05/13/1991 - Training and certification procedures of Hazwoper. - [1910.120; 1910.120(q); 1910.120(q)(6)(v); 1910.120(q)(7); 1910.120(q)(8)]
05/13/1991 - Unfavorable Review Commission Decision. - [1910.107(b)(5)(iv)]
05/10/1991 - Regulations For Cotton Waste Operations - [1910.1000; 1910.1043]
05/10/1991 - Training requirements for employees in food storage facility where ammonia is used solely as a refrigerant. - [1910.120; 1910.120(p)(1); 1910.120(p)(7); 1910.120(p)(8); 1910.120(q); 1910.120(q)(6)(iii); 1910.120(q)(6)(v)]
05/08/1991 - Labeling requirements with regard to containers of pesticides - [1910.1200]
05/08/1991 - MSDS required with initial shipment of chemicals used in humidification systems in office areas - [1910.1200]
05/08/1991 - Requirements for minimum illumination at construction sites. - [1926.56]
05/06/1991 - The posting of notices on the application of certain Federal laws. - [1903.2]
05/01/1991 - Calendar stacks used in the pulp and paper industry - [1910.261; 1910.212]

April

04/24/1991 - Implementation of a comprehensive chemical hygiene plan for lab operations - [1910.1450]
04/24/1991 - Shielding of drive lines on pivotal sprinklers and an interpretation of the words "guarded by location". - [1928.57]
04/19/1991 - Occupational exposure to psittacosis and OSHA's enforcement activity to protect exposed employees.
04/19/1991 - Rollover protective structures for material handling equipment - [1926.1000]
04/19/1991 - Time and resources needed to comply with Lab Standard is justifiable - [1910.1450]
04/18/1991 - Extension Cords Connected to Permanent Wiring of a Construction Site Building - [1926.404(b)(1)]
04/17/1991 - Definition of Reasonable Diligence as stated in 1910.1096(d)(1). - [1910.1096]
04/17/1991 - Retesting when audiogram shows employees have suffered STS shift - [1910.95(g)(7)(ii)]
04/15/1991 - Clarification of Scope of OSHA Instruction STD 1-12.22 - [1910.212(a)(3)(ii)]
04/12/1991 - Acceptable use of the presence sensing device - [1910.216; 1910.303]
04/10/1991 - Separation of LPG containers from "important buildings" in 1910.110 - [1910.110(b)(6)(ii)]
04/10/1991 - Work permits in lockout/tagout standard requirements - [1910.147]
04/09/1991 - Oregon Interagency Migrant Labor Camp Enforcement Agreement - [1975.1]
04/08/1991 - Enforcement of the Chromate and Chromic Acid PEL - [1910.1000]
04/04/1991 - MSDS requirements for scrap materials - [1910.1200(g)]
04/03/1991 - Emergency response in the trucking industry - [1910.120; 1910.1200; 1910.120(q)(1); 1910.120(q)(3)(vii); 1910.120(q)(3)(iv); 1910.120(q)(6); 1910.38; 1910.1200(h)]
04/03/1991 - Favorable Review Commission Decision. - [1910.1020]
04/03/1991 - Location of excessive temperature sensors in the grain industry - [1910.272]
04/02/1991 - Bolt-together, divided wheels are not considered multi-piece rim wheels - [1910.177]
04/01/1991 - Non-finishing spraying of contact cement to wood or to laminae - [1910.107]
04/01/1991 - Occupational noise exposure limits - [1910.95(a)]
04/01/1991 - Use of X-Pac as an explosion suppression system - [1910.272]

March

03/27/1991 - Clarification of approval requirements for equipment to classify underground construction operations as potentially gassy - [1910.7; 1926.800(h)]
03/22/1991 - The Standards do not exclude equipments by weight of the machine for rollover protective structure. - [1926.602; 1926.1000]
03/19/1991 - Enforcement of the Hazard Communication Standard as it relates to "vegetable oil mist" - [1910.1200; 1910.1000 TABLE Z-1]
03/19/1991 - Interpretation of the meaning of "Fixed Jacks" on trailers - [1910.178; 1910.178(k)(3)]
03/13/1991 - Automatic return attachments on radial saws - [1910.213]
03/13/1991 - Employees who design and engineer hazardous waste facilities and their coverage under 1910.120. - [1910.120]
03/07/1991 - Permanent handrail on platform inside a chimney or silo - [1910.22(b)(4); 1910.23(a)(8)]
03/07/1991 - Proper wheel radius in manually propelled carriage to comply with 40 pound limit for horizontal force - [1910.66(f)(3)(i)(C)]
03/06/1991 - A rescue team is required during all phases of underground construction operations in a tunnel. - [1926.800(g)(5)]
03/04/1991 - Clarification of OSHA standard on Overhead and Gantry Cranes - [1910.179]
03/04/1991 - Guidelines for First Aid Training Programs. - [1910.151; 1926.50; 1915.98; 1918.97; 1917.26]
03/04/1991 - Machine Guarding - [1910.212(a)(1)]
03/04/1991 - The excessive space required on job sites to comply with the posting of various posters mandated by Federal law. - [1903.2(a)(3)]

February

02/28/1991 - Use of thermoplastic pipe in above ground locations
02/25/1991 - Training requirements for post-emergency response operations - [1910.120(q)(11)(ii); 1910.1200]
02/22/1991 - Respirators for fire-fighters. - [1910.156(b)(2); 1910.156(c)]
02/19/1991 - Application of the OSHA standards 1910 and 1926 to "Operating Plant Services" - [1910; 1926]
02/15/1991 - Applicability of 1910.120(p)(2) to a RCRA TSD hazardous waste site handling PCB's - [1910.120(p)(2); 1910.1200(b)(6)(i)]
02/13/1991 - Maintenance employees having regular duties in permitted areas are covered by 1910.120(p) - [1910.120(p); 1910.1200]
02/12/1991 - Investigation conducted by OSHA at the Houston Chemical Complex. - [1903.17(a)]
02/12/1991 - OSHA standards that may apply to monorail systems and underhung cranes.
02/11/1991 - Label requirements for crystalline silica - [1910.1200(f)]
02/08/1991 - Coverage of various types of laboratories by the Laboratory Standard - [1910.1450]

January

01/31/1991 - Back-welding of threaded connections in anhydrous ammonia service. - [1910.111; 1910.111(b)(7)(iv)]
01/31/1991 - Peroxides and chlorates in blasting agents, slurries and emulsions - [1910.109(h)]
01/30/1991 - HCP requirements for employers at multi-employer worksites - [1910.1200(e); 1910.1200(h)]
01/30/1991 - Material Safety Data Sheet distribution to retail hardware store customers. - [1910.1200]
01/29/1991 - Rehabilitation of a sewer tunnel constructed in the years between 1926 and 1932 - [1926.800]
01/29/1991 - The intervals between physical examinations for employees performing interior structural firefighting. - [1910.134; 1910.156]
01/29/1991 - The use of fork trucks in plants. - [1910.178(m)(5)(iii)]
01/28/1991 - Application of 1910.120 to emergency Responders at a nuclear power plants - [1910.120]
01/28/1991 - Decontamination of equipment used on hazardous waste sites. - [1910.120(k)]
01/24/1991 - Use of non-approved respirators and improper use of approved respirators - [1910.134(d)(1)(ii)]
01/23/1991 - Application of the Hazardous Waste Operations and Emergency Response to general industry. - [1910.38; 1910.120]
01/23/1991 - Employee emergency alarm systems. - [1910.165; 1910.165(b)(2); 1910.165(b)(3); 1910.165(b)(4); 1910.165(c)(1); 1910.165(d)(3); 1910.164(d)(4); 1910.38; 1919.120(l); 1910.120(q); 1910.7]
01/18/1991 - Sampling for benzidine congener dyes - [1910.1010]
01/17/1991 - Chemical manipulation, production, multiple uses of chemicals in QC Labs - [1910.1200; 1910.1450]
01/17/1991 - Decision in The Hardaway Co. v. Dole Case. - [1910.132(a)]
01/16/1991 - Laboratory Standard's application in testing building products - [1910.1200; 1910.1450]
01/09/1991 - Applicability of the OSHA Laboratory Standard to laboratories within the electric utility industry. - [1910.1200; 1910.1450]
01/09/1991 - Clarification of Standards - [1926 Subpart P; 1926.651; 1926.652]
01/08/1991 - Use of loss control reports prepared by an insurance company for its policyholders, will create a detrimental relationship between the company and the policyholders - [1903.3]
01/03/1991 - QC Labs conduct physicochemical analyses with no altering relating to Quality Control - [1910.1450]