OSHA Issues Seven Interpretation Letters Clarifying Workplace Safety Standards

OSHA Provides Regulatory Guidance for Construction and Industrial Compliance

The U.S. Department of Labor's Occupational Safety and Health Administration has issued seven letters of interpretation clarifying federal workplace safety and health standards. Released on December 10, 2025, these official guidance documents address specific workplace situations and safety requirements affecting construction, engineering, and other industries.

OSHA's Interpretation Letter Program

OSHA's letters of interpretation program provides official explanations of how federal safety and health standards apply to specific workplace situations and hazards. As part of the Trump Administration's emphasis on compliance assistance, these interpretations help employers understand regulatory requirements and maintain safe workplaces.

Deputy Labor Secretary Keith Sonderling stated: 'From construction to engineering, OSHA is providing decisive guidance after gathering feedback from employers, demonstrating our opinion letter program has already been effective. 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.'

Key Interpretation Letters for Construction Professionals

The seven interpretation letters address critical workplace safety topics:

1. Permit Required Confined Space Standards

Clarifies whether employers must drain water from pipes before entering for repairs when a hazard assessment shows no risk of rupture or leaks—relevant for plumbing and mechanical contractors.

2. COVID-19 Recordkeeping and Reporting Requirements

Addresses the enforcement status of OSHA's COVID-19 reporting and recordkeeping requirements under 29 CFR 1910.502, providing clarity on documentation obligations.

3. Powered Industrial Truck Training Program Implementation

Determines whether employees can demonstrate competence in operating powered industrial trucks through live-streamed training sessions—relevant for site safety and equipment operations.

4. OSHA Forms 300 and 300A Software Equivalents

Permits companies to use their own software-generated documents to replace OSHA Form 300 and Form 300A for recordkeeping, streamlining compliance documentation.

5. Engineering Controls for Chemical Safety

Clarifies whether installing bellows valves, leak-proof valves, or double-seal valves qualifies as engineering controls under Benzene and 1,3-Butadiene standards.

6. Audiometric Testing with Cochlear Implants

Explains how audiometric testing requirements apply to workers using cochlear implants, addressing accessibility in hearing protection programs.

7. Stair Angle and Tread Depth Requirements

Specifies whether stairs and treads meeting specific angle and depth dimensions comply with OSHA's stairway standards—critical for construction and facility safety.

Compliance Assistance Initiative

Deputy Secretary Sonderling announced the Department of Labor's opinion letter program in June 2025 to expand compliance assistance across five federal agencies. This initiative reinforces the department's commitment to helping workers, employers, and stakeholders understand how federal labor laws apply to specific workplace scenarios.

Accessing Interpretation Guidance

The public can access OSHA's interpretation letters and submit new interpretation requests through the OSHA Letters of Interpretation page. These guidance documents support compliance and training requirements while helping construction companies and industrial employers maintain safe working conditions.

Industry Impact

For construction professionals and safety managers, these interpretation letters provide authoritative guidance on compliance requirements. Clear explanations of regulatory standards reduce ambiguity and help companies implement effective safety programs that protect workers while maintaining operational efficiency.

Published: December 10, 2025 | Source: U.S. Department of Labor, OSHA