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

12/30/1993 - Applicability of the Process Safety Management manufacturing processes involving workplace explosives. - [1910.109; 1910.119]
12/30/1993 - Eyeglasses with exposed metal parts. - [1910.333]
12/30/1993 - HHCs as it applies to ethylene oxide (ETO). - [1910.119]
12/30/1993 - HHCs as it applies to manufacturing processes involving workplace explosives. - [1910.119]
12/30/1993 - Processes involving workplace explosive. - [1910.119]
12/27/1993 - Fall protection and pipe racks. - [1926.502(d)]
12/22/1993 - The Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard as they apply to veterinary drugs. - [1910.1200]
12/14/1993 - HHCs as it applies to strategic petroleum reserve storage sites. - [1910.119]
12/10/1993 - HHCs as it applies to end use applications of acrolein. - [1910.119]
12/09/1993 - Proper equipment for testing ground-fault circuit interrupters (GFCIs). - [1926.404(b)(1)(ii)]
12/09/1993 - Tunnel boring machine equipment. - [1910.7(a); 1926.449; 1926.403(a); 1926.800(s)]
12/03/1993 - General industry standards to construction activities. - [1926.20(d)(2)]
12/01/1993 - Keller ladder proper set up. - [1926.32; 1926.1060(a)(1)(iii)]

November

11/29/1993 - Hoists that have two upper "hoist limit switches". - [1910.179]
11/24/1993 - Extracted teeth potentially infectious materials. - [1910.1030]
11/23/1993 - The meaning of "direct recirculating ovens". - [1910.263]
11/17/1993 - Steel-toed and steel-shanked tennis shoes for use at a construction site. - [1926.96]
11/15/1993 - Permit-Required Confined Spaces: metal container curing ovens. - [1910.146(c)(7); 1910.147; 1910.146(b)]
11/15/1993 - Using a forklift truck to lift personnel on a secured safety platform with a guardrail. - [1910.67; 1910.178]
11/10/1993 - Crane overload tests must be performed according to the manufacturers specifications and limitations - [1926.550(a)(1)]
11/10/1993 - Employees working on scaffolds and wearing of protective helmets. - [1926.100]
11/09/1993 - Spill containment of flammable or combustible liquids when a curb or earth dike is used. - [1910.12; 1910.106(d)(6)(iii); 1926.152(c)(3)]
11/04/1993 - Hazard evaluation of mixtures containing established mutagens. - [1910.1200]
11/02/1993 - Load testing of underhung trolleys/lifting devices. - [1910.179(b)(2)]

October

10/28/1993 - The soil classification system. - [1926]
10/22/1993 - Permit Required Confined Space Standard as it applies to certain operations. - [1910.146]
10/21/1993 - Permit Required Confined Spaces Standard requires employers to retain canceled entry permits for at least one year. - [1910.146]
10/20/1993 - Elevator repair and servicing. - [1910.146]
10/19/1993 - OSHA Standard on Occupational Exposure to Bloodborne Pathogens. - [1910.1030]
10/15/1993 - Summit's training program on confined space entry. - [1910.146]
10/15/1993 - Who is required to wear the body harnesses and retrieval lines. - [1910.146]
10/12/1993 - Use of battery power operated cleaning equipment in hazardous locations. - [1910.307(c)]
10/08/1993 - The meaning of the word "entrapment" as in the Permit Required Confined Space (PRCS) standard. - [1910.146]

September

09/27/1993 - Hazard warning label requirements. - [1910.1048]
09/27/1993 - OSHA does not endorse commercial products. - [1910.1030]
09/24/1993 - Free standing/boom supported personnel hoist. - [1926.552(c)(3)]
09/24/1993 - Pregnancy care centers administering urine pregnancy tests and the BBP standard. - [1910.1030]
09/23/1993 - Testing requirements as they apply to powered platform installations permanently dedicated to building maintenance. - [1910.66]
09/22/1993 - OSHA's system of inspection priorities. - [1903]
09/20/1993 - Coating processes covered by the PSM standard. - [1910.119]
09/20/1993 - Personal protective equipment, general requirements and employer responsibility. - [1910.132]
09/17/1993 - "Eyelet" and "four-slide" machines are covered by 1910.212. - [1910.212]
09/17/1993 - Clarification of OSHA Policy on Employer Abatement Assistance. - [1903.19]
09/17/1993 - Use of microwave systems to convert regulated waste into waste free of biohazardous material. - [1910.1030]
09/15/1993 - OSHA does not approve or endorse products. - [1910.1030]
09/13/1993 - FDA regulated drugs that pose a hazard would be covered by the HCS. - [1910.1200]
09/13/1993 - OSHA does not regulate the outer shipping container of hazardous material. - [1910.1048]
09/13/1993 - Requirement of name, address and telephone number on an MSDS. - [1910.1200]
09/09/1993 - Employee alarm systems. - [1910.165(b)(5)]
09/09/1993 - HHCs as it applies to Hydrogen Peroxide delivered from a tank truck. - [1910.119]
09/09/1993 - Interpretation of the word "close". - [1910.110(b)(14)(i)]
09/09/1993 - Movement of compressed gas cylinders with regulators installed and "special truck" requirement - [1910.253]
09/09/1993 - Qualified employee requirements for the servicing and maintenance of electrical equipment. - [1910.332(a); 1910.333(b); 1910.333(c)(2); 1910.334(c)(1)]
09/08/1993 - Delivery of hydrogen peroxide, 52% by weight or greater. - [1910.119]
09/07/1993 - Requirement for additional employee training whenever new hazards are identified. - [1910.1200]
09/03/1993 - Secondary wire rope suspension systems. - [1926.451(g)(3)(iv)]
09/03/1993 - Solvents classified as a combustible liquid on the basis of the MSDS - [1910.1200(d); 1910.1200(g)]
09/03/1993 - Wiring, Extension Cords and Grounding. - [1926.404(f)(3)(i)]

August

08/31/1993 - Employee exposure to hazardous chemicals while working around small sensors. - [1910.1200]
08/27/1993 - Enforcement of ventilation requirements for welding operations. - [1910.252(c)]
08/25/1993 - Unit dose syringes. - [1910.1030]
08/24/1993 - All electrical equipment must be approved. - [1910.399]
08/24/1993 - Mineral oil and/or petrolatum containing skin care products and latex gloves. - [1910.1030]
08/19/1993 - Exposure monitoring requirements. - [1910.1001]
08/19/1993 - HHCs as it applies to Hydrocarbon fuels used solely for workplace consumption. - [1910.119]
08/18/1993 - Willful violations for lack of general training in construction. - [1903; 1926.21]
08/13/1993 - MSDS requirements for drugs - [1910.1200]
08/11/1993 - Clarification of the definition of a permit-required confined space (permit space). - [1910.146]
08/09/1993 - Extension cord grounding continuity requirements. - [1926.404(b)(1)(iii)(D); 1926.404(b)(1)(iii)(E); 1926.404(b)(1)(iii)(G)]
08/09/1993 - Labeling requirements for Formaldehyde when used as an insecticide - [1910.1048]
08/06/1993 - Warning stickers on stump grinders. - [1926.200]
08/05/1993 - Compliance and Enforcement Activities affected by the PELs Decision. - [1910.1000; 1910.1000 TABLE Z-1; 1910.1000 TABLE Z-2; 1910.1000 TABLE Z-3]
08/05/1993 - Post-emergency response and medical surveillance requirements of HAZWOPER - [1910.120]
08/04/1993 - Permit-Required Confined Spaces for General Industry. - [1910.146]

July

07/30/1993 - Conflict between requirements of 1910.252 and 1910.146 - [1910.252; 1910.146]
07/28/1993 - Minnesota administers its own occupational Safety & Health Program. - [1910.120]
07/27/1993 - Use of the Racal "Breath-Easy 6" powered air purifying respirator with beards. - [1910.134(g)(1)(i)]
07/24/1993 - Definition of Potentially Gassy Atmosphere. - [1926.800]
07/22/1993 - Permissibility of a consent form with a waiver of liability. - [1910.1030; 1910.1030(g)(2)(vii)(I)]
07/16/1993 - Minimum length that an excavation must be before a protective system is required. - [1926.652(a)]
07/15/1993 - Flammable and Combustible Liquid standard. - [1910.106]
07/13/1993 - Head protection standard. - [1910.135]
07/13/1993 - Work performed in conjunction with insulated enclosures. - [1910.146]
07/12/1993 - Class I lasers. - [1926.54]
07/12/1993 - Custom shoes in an industrial environment. - [1910.136(b); 1926.96]
07/12/1993 - Pump jack scaffold bracing. - [1926 Subpart L]
07/12/1993 - Reverse signal alarms for motor vehicles. - [1926.601(b)(4)(i)]
07/09/1993 - Coverage of Lifeguards. - [1910.1030]
07/09/1993 - Dimethylamine and Anhydrous Dimethlamine and the PSM standard. - [1910.119]
07/09/1993 - Noise exposure standard and impairment adjustments. - [1910.95; 1910.95 App F]
07/07/1993 - Confined Space provisions of 29 CFR 1910.261 in light of the promulgation of 29 CFR 1910.146 - [1910.261; 1910.146]
07/07/1993 - Protocol for blunting a needle against re-use & one-handed recapping prior to discard. - [1910.1030]

June

06/29/1993 - Exposure to hypodermic needles in recycling center. - [1910.1030]
06/28/1993 - Portable and vehicle mounted generators must be "approved" on the job site. - [1926.403; 1926.449]
06/28/1993 - When an OSHA standard references an earlier version of the ANSI standard.
06/25/1993 - Guidelines for platforms and walkways on cranes. - [1910.179(b); 1910.179(d)]
06/25/1993 - MSDS requirements - [1910.1200]
06/24/1993 - Application of standard to more than health care workers - [1910.1030]
06/24/1993 - Sulfuric acid and the PSM standard. - [1910.119]
06/22/1993 - Response to emergency in "normal work area" definition. - [1910.120]
06/21/1993 - After changing protective clothing for a lunch break, it should not be reused for the balance of the shift. - [1926.1101]
06/18/1993 - Modifying a ladder for loads in excess of manufacturer's rated capacity. - [1926.1053(a)(1)(i); 1926.1053(a)(1)(ii)]
06/18/1993 - The wearing of steel-toe shoes by electrical tradesmen. - [1910.136(b); 1926.96]
06/17/1993 - Pulmonary function testing training requirements and spirometer transmission of disease. - [1910.134; 1910.134(c)(1)(ii); 1910.134(e); 1910.1001; 1910.1001(l)(1)(ii)(B); 1910.1028; 1910.1030(a); 1910.1043; 1910.1048]
06/17/1993 - Whether an off-site HAZMAT emergency response team may be permitted to all areas of a hazardous waste site in an emergency response action. - [1910.120]
06/16/1993 - Variance Informational Handout. - [1905.10; 1905.11]
06/15/1993 - Strength of scaffold planking. - [1926.451]
06/14/1993 - Applicability of the Machine Guarding and Lockout/Tagout standards to printing presses - [1910.147; 1910.212; 1910.219]
06/14/1993 - Labeling requirements of hazardous chemicals. - [1910.1200]
06/09/1993 - Black liquor recovery boilers, associated oil (or gas) auxiliary fuel burner systems and PSM. - [1910.119]
06/08/1993 - Sweeper/scrubber equipment is not considered a powered industrial truck. - [1910.178]
06/03/1993 - Industries involved in peanut production. - [1910.272]
06/03/1993 - Use of a powered industrial truck to dump hexamine into a hopper of a bucket elevator. - [1910.178]
06/02/1993 - Coverage of Ear Piercing. - [1910.1030]

May

05/28/1993 - Refresher training requirements. - [1910.119]
05/27/1993 - Are above ground tanks acceptable...in place of diking. - [1910.106]
05/27/1993 - Exposure of trainers and team physicians to body fluids. - [1910.1030]
05/27/1993 - Standpipe and hose systems. - [1910.156; 1910.158]
05/19/1993 - Interpretation of coverage for the telecommunications industry with regard to the new Permit-Required Confined Spaces standard. - [1910.5; 1910.146; 1910.268]
05/18/1993 - OSHA authority over injuries to the public. - [1975.3]
05/15/1993 - Fire extinguisher requirements of Hazard Communication Standard. - [1910.1200]
05/11/1993 - Hazardous substances found in veterinary practices. - [1910.1200]
05/10/1993 - Clarification of paragraphs (c)(5) and (c)(7) of the Permit-Required Confined Spaces standard. - [1910.146]
05/07/1993 - MSDS requirements. - [1910.1200]
05/03/1993 - Fumigants used to control insects in food plants. - [1910.119]

April

04/30/1993 - Dental workers exposed to disinfectants as part of decontamination. - [1910.1030]
04/30/1993 - Toenail particles do not qualify as regulated waste. - [1910.1030]
04/28/1993 - HHC's as it applies to flammable liquid stored at a worksite. - [1910.119]
04/27/1993 - Retract-A-Matic 6 Lifeline as it applies to personal fall arrest system. - [1910.66 App C]
04/22/1993 - Wood dust sampling - [1910.1000]
04/21/1993 - NRTL accreditation of an existing approved lab and a lab with which it has merged. - [1910.7]
04/20/1993 - Clarification on first aid requirements for hazardous waste sites. - [1910.120; 1910.120(e)(3)(ii); 1910.120(l)(2)(viii); 1910.151; 1910.151(b); 1910.1030]
04/20/1993 - Machine guarding requirements as it applies to centrifuges. - [1910.212]
04/19/1993 - Cleaning of police uniforms as specified by bloodborne pathogens standard - [1910.1030]
04/19/1993 - Labeling of products currently under FDA review. - [1910.1030]
04/19/1993 - Portable firefighting equipment. - [1926.150]
04/19/1993 - Toilets are not required at construction jobsites if transportation is readily available to nearby facilities. - [1926]
04/16/1993 - Training requirements for emergency and post-emergency response to marine-based oil spills. - [1910.120(a)(3); 1910.120(q)(6)(iii); 1910.120(q)(6)]
04/14/1993 - Evaluation and use of radiofrequency protective clothing - [1910.132]
04/14/1993 - Interlock requirements for centrifuges. - [1910.212]
04/14/1993 - Propane as a fuel for ovens; Chlorine storage exceeding 1500 pounds. - [1910.119]
04/14/1993 - Respiratory protection as it relates to oil fields - [1910.134]
04/13/1993 - Albumin Human USP and the standard. - [1910.1030]
04/08/1993 - Extension cord equipped with a built-in "continuity tester". - [1910.304]
04/06/1993 - Use of overhead bridge and gantry cranes as work platforms. - [1910.179]
04/02/1993 - Frame grounding of arc welding machines. - [1926.351]
04/01/1993 - Meeting labeling requirements of hazard communication standard for slag wool. - [1910.1200(f)]

March

03/25/1993 - OSHA jurisdiction over employees working in an Indian reservation clinic. - [1975.4(b)(3)]
03/25/1993 - Variance request on conditions surrounding a citation under litigation. - [1926.556]
03/24/1993 - Health and safety plans for hazardous waste operations & emergency response. - [1910.120]
03/24/1993 - Request for approval of guardrail system. - [1926.500]
03/23/1993 - Construction industry general duty clause, and the bloodborne pathogens standard. - [1910.1030]
03/18/1993 - Distance reinforcing steel can protrude before guarding is required. - [1926.701]
03/18/1993 - Use of compressed air when cleaning arsenic and lead contaminated surfaces - [1910.1018(k)(2); 1910.1025(h)(2)]
03/17/1993 - Rulings or requirements for employees in the electrical trade to wear steel-toe shoes. - [1910.333]
03/16/1993 - Use of temporary vertical ladders. - [1926.1053(b)(5)(i)]
03/12/1993 - Hazardous waste operations and emergency response lapsed refresher training requirements. - [1910.120]
03/12/1993 - Iron oxides as used in pigment coloring operations. - [1910.1200(d)(1)]
03/11/1993 - Exposures to polychlorinated biphenyls (PCB's) in lighting equipment. - [1910.1000]
03/11/1993 - Navy gas free engineering program and related failure to abate citation. - [1915.7; 1915.14]
03/04/1993 - Clarification on training for firefighters and HAZWOPER. - [1910.120]
03/04/1993 - Inert gas as it applies to the hazard communication standard. - [1926.59 ]
03/01/1993 - Ethylene oxide tank changing operations. - [1910.1047]

February

02/26/1993 - Housing on floating fish processors and barges. - [1910.142]
02/25/1993 - MSDS requirements for salt. - [1910.1200(g)]
02/24/1993 - OSHA's position regarding compensating time spent taking employer-sponsored medical exams. - [1910.151]
02/19/1993 - Plywood as a substitute for meeting the standard. - [1926.652]
02/16/1993 - Acceptability of X-ray film size 16" X 17". - [1910.1027(l)(4)(ii)(C); 1926.1127(l)(4)(ii)(C); 1910.1018(n)(2)(ii)(A); 1910.1029(j)(2)(ii); 1910.1045(n)(2)(iii)]
02/16/1993 - American Dental Association "Checklist". - [1910.1030]
02/16/1993 - Bracing of masonry block walls. - [1926.706]
02/16/1993 - Ground fault protection for a construction job-site trailer. - [1926.404(b)(1)(i)]
02/16/1993 - Sterilization of spirometry tubing. - [1910.1030]
02/12/1993 - Protective footwear requirements for inorganic arsenic and lead. - [1910.1018; 1910.1025]
02/11/1993 - Blasting operations within completely contained vessel and sunup/sun own requirements. - [1926.900]
02/10/1993 - Product approval.
02/08/1993 - Advertising.
02/03/1993 - Interpretation of the Process Safety Management standard. - [1910.119]
02/02/1993 - Bloodborne pathogens training requirements. - [1910.1030]
02/02/1993 - Outer Continental Shelf lands--OSHA and the U.S. Coast Guard. - [1910.119]
02/01/1993 - Most frequently asked questions concerning the bloodborne pathogens standard - [1910.1030]

January

01/27/1993 - Definition of an "article" under the hazard communication standard. - [1910.1200(b)(6)(iv)]
01/26/1993 - Bloodborne pathogens standard and the construction industry. - [1910.1030]
01/26/1993 - Counting of soiled health care textiles by route sales representatives. - [1910.1030(d)(4)(iv)]
01/26/1993 - Preservation of Criminal Evidence and Acceptability of Dry Cleaning under 29 CFR 1910.1030 - [1910.1030]
01/26/1993 - Recapping of contaminated needles. - [1910.1030(d)(2)(vii)(B)]
01/26/1993 - Registration of sterilants, tuberculocidal disinfectants, and anti-microbial products. - [1910.1030]
01/26/1993 - Support zone personnel at a CERCLA thermal destruction site. - [1910.120]
01/26/1993 - The hotel/motel industry and the bloodborne pathogens standard. - [1910.1030]
01/26/1993 - Training for plant maintenance personnel and HAZWOPER. - [1910.120]
01/21/1993 - Solutions of hydrogen chloride in water do not apply to Process Safety Management Standard. - [1910.119]
01/19/1993 - Rigging equipment for material handling. - [1926.251]
01/18/1993 - When steam boilers fired by flammable liquids or natural gas are subject to the PSM standard. - [1910.119]
01/14/1993 - Transportation of hazardous waste. - [1910.120; 1910.120(q); 1910.1200; 1975.1]
01/13/1993 - Fiberglass tanks for above and below ground storage of flammable and combustible liquids - [1910.106]
01/13/1993 - Review of Rope Grab Knot. - [1910.66 App C]
01/08/1993 - Employee participation requirements of the Process safety management standard. - [1910.119]
01/08/1993 - Steam boilers fired by flammable liquids or natural gas and the PSM standard. - [1910.119]
01/06/1993 - Evaluation of a "generic" Material Safety Data Sheet (MSDS) for copper/copper alloys. - [1910.1200]