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

12/28/1994 - Companies who send their employees to a service station to fill up company vehicles. - [1910.1200]
12/21/1994 - Hazardous Waste Operations and Emergency Response. - [1910.120]
12/20/1994 - Answers to specific questions concerning the permit-required confined spaces standard - [1910.146]
12/20/1994 - Application of the confined spaces standard to the elevator industry. - [1910.146]
12/20/1994 - Machine-guarding requirements - [1910.212]
12/16/1994 - Request for interpretation of the final lead in construction. - [1926.62; 1926.353; 1926.354]
12/14/1994 - Certification of manufactured products intended for use in the workplace - [1910.399; 1910.7]
12/13/1994 - Abortion clinics do not comply with OSHA regulations and guidelines. - [1910.1200; 1910.1030]
12/13/1994 - Clarification of Contaminated Waste Labelling Requirement. - [1910.1030]
12/13/1994 - Interlock of power supply line/fuel supply must not be time delayed. - [1910.263(l)(9)(iv)(a)]
12/07/1994 - The mandate to use one of two pharmacies and whether or not the time it takes to attend a medical appointment is compensable. - [1910.1030]
12/05/1994 - Corrective Change to the Lead in Construction Compliance Directive, CPL 2-2.58. - [1926.62; 1910.1025]
12/05/1994 - Cotton Dust Standard and CD-ROMs for storing medical and exposure records. - [1910.1043]
12/05/1994 - OSHA's hazard communication requirements for the wood products you sell - [1910.1200]
12/02/1994 - Process Safety Management Standard. - [1910.109; 1910.119]
12/01/1994 - Final Rule on Electric Power Generation, Transmission, and Distribution. - [1910.269]
12/01/1994 - Regulations for Exposure to Bloodborne Pathogens. - [1910.1030]

November

11/30/1994 - Process Safety Management of Highly Hazardous Chemicals. - [1910.119]
11/29/1994 - Fall Protection at residential construction sites. - [1926.501(b)(13); 1910.1200(g)]
11/22/1994 - The use of computer-based training to satisfy OSHA training requirements. - [1910.120; 1926.65 ]
11/21/1994 - HCS as it relates to the guidelines described in OSHA's 1986 publication regarding disposal of hospital wastes contaminated with cytotoxic drugs. - [1910.1030; 1910.1200]
11/17/1994 - Clarification on the use of negative pressure glovebags for the removal of asbestos-containing materials. - [1926.1101]
11/17/1994 - Interpretation for treated wood products in regards to paragraphs (f)(2)(i)-(iii) of the HCS - [1910.1200]
11/17/1994 - Occupational Safety and Health Administration's (OSHA) requirements for asbestos removal bags. - [1926.58; 1926.1101]
11/16/1994 - Material Safety Data Sheet (MSDS) requirements for coatings on automobile parts that will be sanded and cut. - [1910.1200]
11/16/1994 - Medical clearance for respirator wearers in emergency response situations. - [1910.120]
11/15/1994 - Letter requesting that OSHA modify its strict application of the standard at 1910.104. - [1910.104]
11/14/1994 - Interpretation of the Process Safety Management (PSM) of Highly Hazardous Chemicals (HHCs) standard. - [1910.119]
11/10/1994 - Requesting a written opinion on the disposal of the needle-less Biojector syringe. - [1910.1030]
11/08/1994 - Clarification on HAZWOPER emergency response training requirements. - [1910.120]
11/08/1994 - Interpretation of the Electrical Power Generation, Transmission, and Distribution standard. - [1910.269]

October

10/19/1994 - Information relating to radial saws. - [1910.213]
10/19/1994 - Medical surveillance provision of the Cadmium standard for previously exposed employees. - [1910.1027]
10/13/1994 - OSHA requirements for sharps containers under the Bloodborne Pathogens Standards. - [1910.1030]
10/11/1994 - Container labelling requirements. - [1910.1200]
10/11/1994 - The acceptability of a computer based, self-paced training program for use in meeting the refresher training requirements of the standard. - [1910.120]
10/06/1994 - Labelling, training and material safety data sheet and the Hazard Communication standard. - [1910.1027; 1910.1200]
10/04/1994 - PSM clarification on flammable lubrication in aerosol cans, to prevent foods from sticking to heated cookware - [1910.119]

September

August

08/31/1994 - Review and comment on generic labels and consumer information sheets for chromated copper arsenate (CCA) pressure-treated lumber. - [1910.1200]
08/31/1994 - The acceptability of your "FAX-on-demand" system for providing copies of material safety data sheets (MSDS). - [1910.1200]
08/24/1994 - Application of OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard to employers of news media personnel who are covering emergency response incidents. - [1910.120]
08/24/1994 - Interpretation of 29 CFR 1910.142(d)(2) and 1910.142(d)(8) Privies Lighting, Ventilation and Window Space Standards. - [1910.142]
08/22/1994 - Guidance to Compliance Officers for Focused Inspections in the Construction Industry. - [1926]
08/22/1994 - Review of Potential 1926.95(a) Citation for Fall Protection in Steel Erection. - [1926.95]
08/18/1994 - Explosives and Blasting Agents. - [1910.109]
08/17/1994 - Materials used for constructing guardrails. - [1926.702]
08/17/1994 - OSHA standard addressing the materials used for constructing guardrails. - [1926.702]
08/12/1994 - Applicability of the bloodborne pathogens standard to tag attachment devices in garment industries. - [1910.1030(a); 1910.1030(b); 1910.1030(c)(2)]
08/12/1994 - Specifications for rubber insulating gloves based on ASTM standard. - [1910.137]
08/11/1994 - Interpretation on the Cadmium Standard with Respect to Interpreting Air Sampling Data for Establishing Acceptable Work Areas for Medically Removed Workers. - [1910.1027]
08/11/1994 - Permit-required confined spaces. - [1910.146]
08/11/1994 - Requirements for emergency eyewash stations in retail autoparts stores - [1910.132; 1910.133; 1910.151; 1910.303; 1910.307]
08/08/1994 - A crane may be used for rated load testing of below-the-hook lifting device provided the test does not exceed 125% for the crane's rated load. - [1910.179]
08/08/1994 - Permit space entry - [1910.146; 1910.268; 1910.269]
08/08/1994 - Wedge Sockets Wire Rope Clips (Piggy-Back Clip). - [1926.800]
08/05/1994 - The list of hazardous chemicals are required under 1910.1200. - [1910.1200]
08/04/1994 - Requirement for safety nets for steel erection. - [1926.105(a)]
08/04/1994 - Training material for first aid and CPR training. - [1910.151]
08/01/1994 - Clarification of the policy for classifying violations as repeated, as well as clarification of specific regulations. - [1910.95]

July

07/26/1994 - Medical and First Aid standards. - [1926.50]
07/26/1994 - OSHA Policy Regarding Voluntary Rescue Activities. - [1903.14(f)]
07/26/1994 - Wire rope clips in conjunction with wedge sockets. - [1926.800]
07/18/1994 - Clarification of electric power generators, transmission and distribution standard - [1910.269]
07/18/1994 - Process Safety Management - Threshold quantity is determined on the amount of HHC in the process. - [1910.119]
07/15/1994 - The coverage of household products in a small group home. - [1910.1200]
07/13/1994 - Order of testing for permit spaces. - [1910.146]
07/11/1994 - The Process Safety Management (PSM) of Highly Hazardous Chemicals (HHC) standard. - [1910.119]
07/08/1994 - Rollover protective structures for the Cary-Lift model. - [1910]
07/07/1994 - Management and supervisors' training required in paragraph (e)(4) of the standard. - [1910.120]
07/05/1994 - Carbon Monoxide or High Temperature Alarm Requirement for Portable Breathing Air Compressors. - [1910.134(i)(7)]
07/01/1994 - Appropriate quality standards for PPE. - [1910.1030]

June

06/29/1994 - HHC's as it applies to employer obligation to obtain and evaluate information regarding the contract employer's safety performance and programs - [1910.119]
06/24/1994 - MSDSs must be distributed to customer with shipment of chemical. - [1910.1200]
06/22/1994 - HHC's as it applies to pulp and paper industry processes that contain chlorine dioxide - [1910.119]
06/21/1994 - Applicability of 1910.1030 to establish human cell lines. - [1910.1030]
06/16/1994 - Clarifications of the OSHA standards 1910.109 and 1910.119. - [1910.109; 1910.119]
06/15/1994 - Cadmium biological monitoring. - [1910.1027; 1915.1027; 1926.1127]
06/15/1994 - Spray finishing using flammable and combustible materials. - [1910.107]
06/13/1994 - Clarification of the terms "direct staring" and "incidental observing". - [1926.54(j)]
06/10/1994 - Decontamination of a plush carpet surface after a spill. - [1910.1030; 1910.1030(d)(4)(ii)(A)]
06/03/1994 - HHC's as it applies to exterior, interior tanks. - [1910.119]
06/02/1994 - Highly Hazardous Chemical's anhydrous ammonia (NH(3)). - [1910.119]
06/01/1994 - Applicability of OSHA's PRCS standard to gas industry. - [1910.146; 1975.1]
06/01/1994 - HHC standard as it applies to threshold quantity. - [1910.119]

May

05/25/1994 - Highly Hazardous Chemicals, types of hardware that see contact with explosives. - [1910.119]
05/25/1994 - Permit-required confined space standard does not apply where DOT/OPS regulations apply to working conditions. - [1910.146]
05/25/1994 - Respirator Exhalation Valve Leakage. - [1910.134]
05/24/1994 - Natural fabrics and synthetic materials that are acceptable under the electric power generation, transmission and distribution standard. - [1910.269]
05/23/1994 - OSHA's does not enforce the physical qualification requirements of ANSI standards. - [1910.6]
05/19/1994 - OSHA regulation requiring foot protection for employees exposed to falling object hazards. - [1926.95]
05/18/1994 - Highly Hazardous Chemicals as it applies to aqueous solutions of hydrofluoric acid. - [1910.119]
05/13/1994 - Bloodborne pathogens standard applies to employees performing maintenance activities which involve making or keeping a structure, fixture, or foundation. - [1910.1030]
05/09/1994 - Hearing conservation standard questions. - [1910.95]
05/09/1994 - Permit Required Confined Space Standard as it relates to rescue services. - [1910.146]
05/05/1994 - Alternative procedures for the non-entry rescue provision. - [1910.146]

April

04/29/1994 - Recapping of contaminated needles. - [1910.1030]
04/28/1994 - Highly Hazardous Chemicals as it applies to what constitutes the boundaries of a process. - [1910.119]
04/27/1994 - Occupational health hazards to veterinarians. - [1910.1000; 1910.1200; 1910.1030; 1910.101]
04/26/1994 - Bags for collecting and disposing of asbestos waste. - [1910.1001(k)(6); 1926.1101(l)(2)]
04/26/1994 - HAZWOPER and Asbestos standards apply to any emergency response to an uncontrolled hazardous substance release involving the presence of asbestos. - [1910.120; 1926.1101]
04/26/1994 - Is a physician's order required before performing blood testing on a source individual after consent is obtained. - [1910.1030]
04/26/1994 - Labeling required if the content of cadmium is 0.1 percent or greater. - [1910.1027]
04/25/1994 - Breathing air: testing and carbon monoxide alarm. - [1910.134(i)]
04/25/1994 - Field Sanitation Standard. - [1928.110]
04/25/1994 - The employer should make the determination whether the reusable or the disposable device better satisfies requirements of Bloodborne Pathogens standard. - [1910.1030]
04/22/1994 - Highly Hazardous Chemicals as it applies to threshold quantity (TQ) of HHCs. - [1910.119]
04/20/1994 - Mechanical power press brake system monitoring requirements. - [1910.217]
04/15/1994 - Hatch Net 120 fall protection system - [1910.23(a)(3); 1910.23(a)(8); 1918.31; 1926.501(b)(4)]
04/12/1994 - Boat captain be considered the employer of divers if the captian had the power to exercise control over the divers. - [1905.11; 1910 Subpart T]
04/07/1994 - Whether containers which meet the criteria of the U.S. Department of Transportation Infectious Substance Regulations. - [1910.1030]
04/06/1994 - Wet floors due to weather conditions or the entry of vehicles containing melting snow. - [1910.22]
04/01/1994 - The wearing of gloves during routine vena punctures. - [1910.1030]

March

03/31/1994 - Hazard Communication Standard (HCS) requirements. - [1910.1200]
03/31/1994 - Highly Hazardous Chemicals standard, Tertiary Butyl Hydroperoxide (TBHP). - [1910.119]
03/31/1994 - Manually operated winch and tripod system used for raising, lowering and supporting employees. - [1910.28; 1926 Subpart L]
03/31/1994 - Secondary container for a specimen. - [1910.1030]
03/31/1994 - Standard requirements for eyewash and shower equipment, personnel and other protective equipment and air circulation fans, used in an automotive battery charging area - [1910.132; 1910.133; 1910.151; 1910.178; 1910.303; 1910.307]
03/28/1994 - Proper procedures for stacking materials at construction sites. - [1910.176; 1926.250]
03/28/1994 - Safety Procedures During Gunite and Shotcrete Pool Construction. - [1926.652]
03/25/1994 - OSHA does not certify first aid training programs, instructors or trainees. - [1910.151]
03/23/1994 - Reinforcing steel of any diameter and any length must be guarded. - [1926.701(b)]
03/18/1994 - Permit-Required Confined Spaces standard. - [1910.146]
03/18/1994 - Removal from service criteria for wire rope slings. - [1910.184]
03/18/1994 - Stair units manufactured to be used as an integral part of the welded frame scaffolds system. - [1926 Subpart X]
03/16/1994 - Highly Hazardous Chemicals as it applies to flammable liquid from a stationary tank. - [1910.119]
03/10/1994 - Highly Hazardous Chemicals as it applies to a covered process. - [1910.119]
03/10/1994 - OSHACT cannot directly protect employees of State and local governments. - [1975.5]
03/09/1994 - Highly Hazardous Chemicals as it applies to operating procedures and certify on an annual basis. - [1910.119]
03/04/1994 - NIOSH Respirator User Notice.

February

02/23/1994 - Safety procedures associated with the use of wheel or track propelled excavators. - [1926.21(b)(2)]
02/23/1994 - Storage of flammable and/or combustible liquids. - [1926.152; 1926.103; 1910.134]
02/18/1994 - ANSI standard requires Safety-Toe safety shoes meet a compression test and an impact test. - [1910.136]
02/17/1994 - Material Safety Data Sheet (MSDS) provisions. - [1910.1200]
02/15/1994 - Remote distance, close proximity and other PSM questions. - [1910.119]
02/10/1994 - Application of 29 CFR 1926.51(f) - [1926.51]
02/10/1994 - Use of synthetic fiber slings. - [1926.251]
02/09/1994 - Labeling provisions. - [1910.1200]
02/03/1994 - Employers' responsibilities towards temporary employees. - [1910.1200]
02/02/1994 - Hazard determination for carcinogenic compounds - [1910.1200]
02/02/1994 - Labels and hazard warnings. - [1910.1200]
02/01/1994 - Hazard Communication Standard and Material Safety Data Sheets. - [1910.1200]

January

01/31/1994 - Highly Hazardous Chemicals as it applies to solid propellant rocket motors. - [1910.119]
01/31/1994 - Members of a HAZMAT team. - [1910.120]
01/31/1994 - Working distances between employees and energized conductors. - [1926.950]
01/28/1994 - All electric tools need to be tested by a qualified national testing laboratory and be listed and labeled - [1926.449; 1926.302(a); 1926.403(a); 1926 Subpart K]
01/28/1994 - Highly Hazardous Chemicals applies to aqueous solutions of Hydrogen Fluoride. - [1910.119]
01/27/1994 - Demolition regulations do apply to the removal of ceilings and interior non-load bearing walls and partitions - [1926.850(a); 1926 Subpart T; 1926 Subpart L]
01/26/1994 - Exemption from wearing hard hats. - [1910.132; 1910.135]
01/26/1994 - Highly Hazardous Chemicals as it applies to "Dowtherm". - [1910.119]
01/19/1994 - Passenger seat belts not required on school buses - [1926.601(b)(9)]
01/14/1994 - Posting of the OSHA notice;jurisdiction over state and military personnel - [1903.2(a); 1975.5; 1952; 1960.1(e)]
01/14/1994 - Using compressed air for cleaning an employee's body and clothing - [1910.242; 1910.242(b); 1917.154]
01/13/1994 - Confined space entry. - [1910.146]
01/10/1994 - Respirator selection requirements prescribed in the OSHA standard on benzene exposure. - [1910.1028]
01/10/1994 - Soil classification. - [1926 Subpart P]
01/03/1994 - Hazard communication standard and pharmaceuticals - [1910.1200; 1910.1200(b)(6)(v); 1910.1200(b)(6)(vi); 1910.1200(b)(6)(viii); 1910.1200(g)(1)]
01/03/1994 - Release of hazardous chemicals from gas calibration bottles. - [1910.1200]