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

12/31/1997 - Stay-of-enforcement of lead standard for brass and bronze ingot manufacturing. - [1910.1025(e)(1)]
12/30/1997 - Manufacturer and employer responsibilities when providing MSDSs electronically. - [1910.1200; 1926.59 ]
12/22/1997 - Permit-Required Confined Spaces Standard. - [1910.146]
12/18/1997 - Electrical Conductor Identification. - [1910 Subpart S; 1910.269; 1910.303; 1910.304; 1910.399]
12/12/1997 - Electrical hazardous area classification drawings in the workplace. - [1910.119; 1910.307]
12/12/1997 - The storage of flammable liquids in plastic containers. - [1910.106]
12/04/1997 - Fall protection and access for scaffold erecting and dismantling. - [1926.451(g)(2); 1926.451(e)(9)]

November

11/25/1997 - Scaffolds: removal of bracing; maximum loads; damaged planking; and foundations. - [1926.451(c)(2)(iii); 1926.450(b); 1926.451(a)(1); 1926.451(f)(4); 1926.451(c)(2)]
11/19/1997 - Carcinogen status of titanium dioxide relative to OSHA Standards - [1910.1200]
11/19/1997 - Material Safety Data Sheets (MSDSs). - [1910.1200]
11/13/1997 - Alternatives to latex or vinyl may be used for protective gloves to comply with the OSHA Bloodborne Pathogens standard. - [1910.1030]
11/13/1997 - Electronic monitoring system for complying with the confined space standard. - [1910.146]

October

10/31/1997 - Application of HAZWOPER. - [1910.120]
10/31/1997 - Clarification of the requirements of the Hazardous Waste Operations and Emergency Response Standard - [1910.120]
10/31/1997 - Routine asbestos inspections, bulk sampling activities, and training with regards to specific provisions in the Occupational Exposure to Asbestos Standard. - [1926.1101]
10/29/1997 - Access to employee exposure and medical records. - [1910.120; 1910.1020]
10/29/1997 - The requirements of paragraph (m) in the OSHA HAZWOPER Standard. - [1910.120]
10/28/1997 - Application of glove monitoring devices to aid in the detection of gloves that fail during medical procedures. - [1910.1030]
10/22/1997 - Conditions where OSHA might accept a product that is not approved by NIOSH. - [1910.134]
10/22/1997 - Interpretation of the machine guarding requirements. - [1910.211; 1910.215]
10/21/1997 - A centralized repository for the electronic collection and dissemination of MSDSs. - [1910.1200]
10/21/1997 - Inspection certification record requirements in overhead and gantry cranes. - [1910.179]
10/03/1997 - Use of latex surgical exam gloves for protection from glutaraldehyde. - [1910.138]

September

09/25/1997 - Safe Medical Systems' SNR sharps collection system. - [1910.1030]
09/23/1997 - The Bloodborne Pathogen Standard and the Enforcement Procedures for TB. - [1910.1030]
09/18/1997 - Responsibility of each person involved in Class I glovebag removal operations. - [1926.1101]
09/09/1997 - Clarification of the Electrical Standard as it applies to flexible power cords on appliances. - [1910.303(a); 1910.305(a)(2)(i); 1910.305(g); 1910.305(g)(1)(iii)(A); 1910.334(a)(2); 1910 Subpart S]
09/09/1997 - Testing electrical resistance of grain elevator conveyor belts. - [1910.272]
09/03/1997 - Construction Asbestos Standard. - [1910.1001; 1915; 1926.1101]

August

08/31/1997 - Annual training required by the occupational exposure to bloodborne pathogen standard. - [1910.1030]
08/28/1997 - The effect of workers' compensation claims on temporary medical removal protection benefits. - [1910.1025]
08/27/1997 - Employment of individuals with disabilities.
08/20/1997 - Asbestos surveying and sampling associated with the remodeling, renovation, and demolition of buildings. - [1926.1101]
08/14/1997 - Electronic recordkeeping of employee safety training records. - [1910; 1915; 1917; 1918; 1926; 1928; 1960]
08/12/1997 - Access steps or ladders for getting on and off a flatbed trailer. - [1926.1050; 1926.1051; 1926.1060]
08/07/1997 - OSHA's requirements for enclosed hardware used in 'third rail' ladder safety devices for towers. - [1910.27; 1910.268; 1926.105; 1926.1053]
08/05/1997 - A letter of determination of the new scaffold mandate. - [1926.454]
08/01/1997 - Construction Asbestos Standard. - [1926.1101]

July

07/15/1997 - Powered platforms permanently dedicated for building maintenance standard. - [1910.66]
07/15/1997 - Vehicle-mounted elevating and rotating work platforms standard. - [1910]
07/08/1997 - Means of Egress. - [1910]
07/08/1997 - Roll-over protective structures for agricultural wheeled tractors. - [1928.51]
07/08/1997 - Service workers in the heating, plumbing and air-conditioning industries. - [1910; 1910.12; 1926.13]
07/07/1997 - Petition for modification of OSHA's Methylene Chloride Standard - [1910.1052]
07/03/1997 - OSHA's Methylene Chloride Standard - [1910.1052]
07/03/1997 - OSHA's standard for exposure to bloodborne pathogens. - [1910.1030]
07/01/1997 - NIOSH approved respirator during the period of an employee's escape from a chemical release of phosgene. - [1910.134(d)(1)(ii)]

June

06/30/1997 - Sodium Azide as Used in the Manufacturing Process of Automobile Air Bags. - [1910.109; 1910.119]
06/27/1997 - Hydrogen fuel that is contained in fuel storage cylinders. - [1910.103]
06/27/1997 - OSHA's Hazardous Waste Operations and Emergency Response Standard. - [1910.120]
06/27/1997 - OSHA's Methylene Chloride Standard - [1910.1052]
06/27/1997 - OSHA's position on U.S. Environmental Protection Agency-approved disinfectants. - [1910.1030]
06/25/1997 - Requirements for negative pressure rooms.
06/23/1997 - Clarification o-f the electric power generation, transmission, and distribution standard. - [1910.269]
06/20/1997 - Provisions of the Hazard Communication Standard. - [1910.1200]
06/20/1997 - SCBA cylinder interchangeability. - [1910.134(d)(1)(ii); 1910.156(f)(1)(iv); 1910.120(q)(3)(x)]
06/16/1997 - Association between toluene and Pierre Robin Syndrome. - [1915.1000]
06/16/1997 - Internet use for posting Material Safety Data Sheets (MSDSs). - [1910.1020]
06/15/1997 - Scaffolds used in the Construction Industry. - [1926; 1926.451]
06/11/1997 - Appropriateness of computer-based interactive training programs to satisfy required OSHA training. - [1910.1030]
06/10/1997 - OSHA regulation on "piped" potable water supply. - [1910.141; 1928.110]
06/05/1997 - OSHA's Methylene Chloride Standard - [1910.1052]

May

05/29/1997 - A hazardous chemical is any chemical which is a physical hazard or a health standard. - [1910.132; 1910.1200]
05/29/1997 - Mushroom Style Plastic Rebar Covers Used For Impalement Protection. - [1926.701]
05/29/1997 - Using 1992 data to "program" inspections. - [1960]
05/28/1997 - Reporting over-the-road fatalities; Refusing entry and employee interviews to an OSHA inspector; and OSHA's policy associated with seat belts on forklift trucks - [1903.10; 1903.3; 1903.4]
05/19/1997 - Fall protection for employees climbing or moving on preassembled reinforcing steel assemblies. - [1926.501]
05/16/1997 - 1910.119 does not apply to public displays of flame effects. - [1910.119]
05/16/1997 - OSHA's enforcement policy to protect workers against glutaraldehyde exposure.
05/15/1997 - Clarification of the definition of a hazardous chemical and the requirements for Material Safety Data Sheets. - [1910.1200]
05/15/1997 - Glove bag methods for control of exposure to airborne asbestos. - [1926.1101]
05/15/1997 - OSHA's regulations for chemicals used in the workplace, and in particular, glutaraldehyde. - [1910.1000; 1910.1200]
05/15/1997 - Permissible Exposure Limits for Nuisance dust. - [1910; 1910.134; 1910.1000]
05/15/1997 - Requirements for labeling portable fire extinguishers. - [1910.1200]
05/12/1997 - Coverage of Stored Flammables Under the Process Safety Management Standard. - [1910.119(a)(1)(ii)(B); 1926.64(a)(1)(ii)(B); 1910.106]
05/12/1997 - Electrical standards and the application to electrically-powered medical devices. - [1910 Subpart S]
05/12/1997 - Introduction of electrical welding equipment into a non-permit confined space. - [1910.146; 1910.252; 1910.252(a)(4)(i); 1910.252(b)(4)(i); 1910.252(b)(4)(vii); 1910.252(c)(4); 1910.252(c)(9); 1910.252(c)(10); 1910 Subpart Q]
05/05/1997 - Requirements for dual purpose mechanical equipment (digger derrick and aerial lift). - [1910.67; 1926.453]
05/05/1997 - The use of particulate filters and respirators. - [1910.134(d)(3)(iv)(B)]

April

04/29/1997 - The Process Safety Management Standard. - [1910.119; 1926.64]
04/28/1997 - Classification of asbestos work for employees performing asbestos inspections and obtaining bulk samples. - [1926.1101]
04/28/1997 - Sheetrock and joint compound. - [1910.1001; 1915; 1926.1101]
04/25/1997 - Emergency response training requirements for hospital staff. - [1910.120]
04/24/1997 - Concern over the quality of care given to patients by dentists. - [1975.1]
04/18/1997 - Lack of public awareness of the limitations of eyewashes; review of new product, The Eye Irrigator(TM). - [1910.133; 1910.151(c)]
04/17/1997 - Applicability of the Bloodborne Pathogens Standard for employees who work as companion-sitters in private homes. - [1910.1030]
04/17/1997 - Citations for the wearing of short pants by employees engaged in hot tar and asphalt construction work. - [1926.28; 1926.95]
04/17/1997 - OSHA's asbestos standard regulates working with materials containing less than 1 percent asbestos. - [1926.1101(b); 1926.1101(f); 1926.1101(g)]
04/16/1997 - Fall protection in a situation regarding floor/roofing openings. - [1926.501; 1926.502]
04/11/1997 - Powered industrial truck modifications and approval. - [1910.178(a)(4)]
04/08/1997 - Requirements for electrical wiring in supply and disposal function warehouses containing hazardous materials. - [1910.38; 1910.106(d); 1910.106(e)(7); 1910.106(e)(7)(i)]
04/08/1997 - The airflow rate required for a spray painting area. - [1910.94(c); 1910.107; 1910.38; 1910.39]
04/04/1997 - The government's handling of workers' reports of exposure to hazardous chemicals in the workplace. - [1910.1200]
04/03/1997 - Appropriate protective clothing for aircraft firefighting. - [1910.120; 1910.156]
04/01/1997 - Disinfectants claiming efficacy against the Hepatitis B virus. - [1910.1030]
04/01/1997 - Employee safety and the laundering of contaminated clothing. - [1910.1025]

March

03/31/1997 - Additional Enforcement Policy Change for Respiratory Protection Required for Abrasive Blasting. - [1910.134; 1926.62]
03/26/1997 - The requirements for disposal of contaminated waste once the needle has been destroyed. - [1910.1030]
03/26/1997 - The use of telephones in training to meet the requirements of the Bloodborne Pathogens standard. - [1910.1030]
03/21/1997 - Fall protection in lieu of personal fall arrest systems and the need for a rescue skiff. - [1926.106; 1926.502]
03/21/1997 - Longitudinal bracing across the inner and outer rows of posts on tube and coupler scaffolds. - [1926.452]
03/18/1997 - OSHA Lead Standards, both General Industry and Construction. - [1926.62; 1910.1025]
03/12/1997 - OSHA's policy for scheduling occupational fatality investigations. - [1903]
03/07/1997 - Ridge hook-supported ladders. - [1926.451(e)(2); 1926.1053]

February

02/28/1997 - Akzo-Nobel Chemicals - Limits of a Process - [1910.119]
02/28/1997 - EPA-Registered disinfectants for HIV/HBV. - [1910.1030]
02/28/1997 - Hard-line communication equipment for use in the PRCS standard. - [1910.146]
02/27/1997 - Clarification on entitlement of a copy of energy control program documentation at meat packing plant. - [1910.147; 1910.1020]
02/27/1997 - Evaluation of an employee's ability to perform servicing of multi-piece or single piece rim wheels. - [1910.177]
02/25/1997 - PVC used in window frames and siding. - [1926]
02/24/1997 - Duties of the competent person during the erecting, dismantling and moving of scaffolds. - [1926.451]
02/24/1997 - Placement of the noise dosimeter microphone for measuring the noise exposure of an employee using an airline respirator equipped with a shroud. - [1910.95]
02/24/1997 - Scaffolds used in the Construction Industry. - [1926]
02/21/1997 - OSHA does not have regulations that apply to residential properties. - [1926.10]
02/20/1997 - Manufacturers' use of the Internet for distribution of MSDSs to downstream users. - [1910.1200(g)(6); 1910.1200(g)(7); 1910.1200(g)(8)]
02/19/1997 - An interpretation of the electric power generation standard - [1910.269]
02/07/1997 - Compliance with OSHA's Asbestos Standard - Composite Bulk Samples. - [1926.1101]
02/07/1997 - Hazard Communication Standard. - [1910.1200(g)(6)]
02/06/1997 - The dental industry's concerns regarding compliance with certain provisions of the Hazard Communication Standard (HCS). - [1910.1200]
02/05/1997 - OSHA Asbestos standard. - [1926.1101]

January

01/30/1997 - Information required on Material Safety Data Sheets (MSDSs). - [1910.1200]
01/30/1997 - Material Safety Data Sheets. - [1910.1200; 1910.1200(g)(1); 1910.1200(g)(8)]
01/28/1997 - Fall protection for the entertainment industry under the OSH Act of 1970. - [1910 Subpart D; 1910.132; 1910.12]
01/24/1997 - Cross-view back-up mirrors on delivery trucks - [1910]
01/23/1997 - Calculation methods used under the air contaminants standard for extended work shifts. - [1910.1025; 1926.62]
01/14/1997 - Clarification of the OSHA standards applicable to H. VIR (inspection) Windows installed in electrical equipment enclosures. - [1910.399]
01/14/1997 - Training provisions of OSHA's HAZWOPER standard. - [1910.38; 1910.120]
01/10/1997 - Use of gasoline in underground construction. - [1926.800(m)(5)]
01/07/1997 - Overlap between FDA and OSHA in the regualtion of dental devices. - [1910.1200]
01/03/1997 - Clarification of overhead and gantry cranes. - [1910.179]