Authority and legal citations

OSHA's General Industry standards in Subpart A are issued under federal statutes and specific Secretary of Labor's orders, and that legal authority is listed in the Subpart A preamble. The Occupational Safety and Health Act sections and Secretary of Labor's Order numbers supporting these standards are cited in 29 CFR Subpart A - Authority and legal citations.

• The Subpart A text specifically references statutory authority such as 29 U.S.C. 653, 655, and 657 and lists multiple Secretary of Labor's Order numbers (for example, Orders 12-71, 8-76, 9-83, 1-90, and later orders).
• Employers and compliance officers should rely on the citations in 29 CFR Subpart A to trace the legal basis for OSHA standards and rules.

Yes — when OSHA incorporates a consensus standard by reference, following that consensus standard is treated as complying with the OSHA requirement it addresses. See 1910.6 for OSHA's rules on incorporation by reference.

• Incorporated consensus standards listed in 1910.6 become enforceable parts of the OSHA rules unless OSHA says otherwise.
• Employers may use those consensus standards to comply with the referenced OSHA requirement, but they remain obligated to meet the exact requirements of the OSHA standard that incorporated them (and to maintain any records or procedures the OSHA standard requires).

OSHA recognizes national consensus standards and may rely on accredited organizations in developing and referencing standards; the rules for this process are set out in 1910.7.

• 1910.7 explains how OSHA incorporates voluntary consensus standards by reference and the role of recognized organizations in that process.
• Employers using consensus standards that OSHA has incorporated should confirm the specific edition OSHA incorporated and follow that edition for compliance.

Yes — 1910.7(f) authorizes certain fee-related actions described in the rule text and identifies statutory authorities supporting those actions; see 1910.7(f).

• 1910.7(f) lists additional statutory authorities under which certain parts of 1910.7 are issued (for example, 31 U.S.C. 9701 and OMB Circular A-25).
• Employers and organizations involved in accreditation or standards services should review 1910.7(f) to understand the legal basis for any fee-related policies or actions referenced there.

Employers must make applicable OSHA standards available to employees and interested parties as required under the statute and section text; see 1910.8.

• 1910.8 addresses how OSHA standards are made available and the legal effect of those standards.
• In practice, employers should ensure employees can access the OSHA standards that apply to their job duties (for example, by providing copies, posting summaries where required, or giving access to electronic copies).

Yes — 1910.9 explains how OSHA standards and related documents can be presented in evidence, and it sets the rules for doing so; see 1910.9.

• 1910.9 clarifies the status of official OSHA materials in proceedings and how parties may rely on them.
• Employers should retain and be prepared to present the relevant OSHA standards and any incorporated consensus standards when responding to inspections, citations, or legal challenges.

Yes — the Subpart A authority statement includes a chronology of Federal Register notices showing when the rule text and updates were published, and that is documented in 29 CFR Subpart A.

• The Subpart A page lists many Federal Register entries (for example, 58 FR 35308, June 30, 1993; 61 FR 5507, Feb. 13, 1996; through more recent entries such as 85 FR 8731, Feb. 18, 2020).
• Those FR citations help users trace the regulatory history and understand when specific amendments became effective; employers and counsel often consult them when interpreting an OSHA change.

No — OSHA announced it will not enforce the Healthcare ETS COVID-19 recordkeeping and reporting requirements effective immediately and until further notice, as explained in the February 5, 2025 memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05.

• The memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 states OSHA will not cite employers for violations of the Healthcare ETS recordkeeping provisions at 29 CFR 1910.502(q)(2)(ii) and related subsections, or for reporting under 1910.502(r), while the enforcement stay is in effect.
• The memorandum also clarifies that OSHA will continue to enforce applicable recordkeeping and reporting requirements under 29 CFR part 1904 (the standard codified elsewhere), so employers must still comply with part 1904 requirements.

OSHA advises that remediation activities involving asbestos-containing building materials (ACBM) are generally covered by the construction asbestos standard, 29 CFR 1926.1101, rather than the general industry asbestos standard; see the November 14, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 explains that repair and remediation activities involving ACBM (including many operations in residential homes) fall under the construction standard [29 CFR 1926.1101] and points to a related 2001 letter for background.
• Employers conducting property remediation should evaluate whether their work meets the construction standard's scope and follow the specific requirements of 1926.1101, including exposure assessment, controls, training, and recordkeeping for construction work with asbestos.

You may temporarily re-energize equipment to test or position it, but only after following the sequence and protections described in the lockout/tagout standard and explained in OSHA's October 21, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 relies on the procedures in 29 CFR 1910.147(f)(1) and requires that employers: clear tools and materials, remove employees from the danger area, remove lockout/tagout devices as specified, energize only for the minimal time needed while providing effective employee protection during testing or positioning, then de-energize and reapply lockout/tagout if additional servicing is needed.
• Employers must document and follow these steps in sequence to protect workers during brief energized operations and must not use this exception to avoid full lockout/tagout during other servicing activities.

No — handrails are not considered vertical barriers or obstructions when measuring the minimum standard stair width under 1910.25(c)(4), as explained in OSHA's October 17, 2024 letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 explains that the required minimum width (22 inches) is measured between vertical barriers such as stair rails, guardrails, and walls, and that handrails are not counted as a vertical barrier for this measurement.
• Employers should therefore measure stair width between actual vertical barriers and not deduct handrail projections from that 22-inch minimum.

Yes — OSHA concluded that servicing vehicles that use C-type light truck tires may be covered by 29 CFR 1910.177 depending on the service methods and equipment, and noncompliance may be treated as de minimis in some cases, as explained in the August 1, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 notes that 1910.177 applies to servicing multi-piece and single-piece rim wheels on larger vehicles and that C-type tires share features with LT tires; OSHA indicated a fact-specific determination is needed and that some deviations may be considered de minimis if they do not directly affect safety.
• Employers servicing C-type tires should compare methods, installation equipment, and servicing practices to those for LT tires and consult the 1910.177 text and OSHA guidance to determine compliance.

Yes — civilian employees working on non-uniquely military operations at Air Force facilities are covered by OSHA standards, and OSHA's Respiratory Protection Standard treats oxygen-deficient atmospheres (below 19.5% O2) as immediately dangerous to life and health (IDLH), as discussed in the July 16, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16.

• The July 16, 2024 letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16 explains that while purely military personnel and uniquely military systems are excluded from OSHA by Executive Order 12196 and Part 1960, civilian employees working on comparable operations are covered and must meet [29 CFR 1910.134] respiratory protection requirements (including recognizing oxygen-deficient atmospheres below 19.5% as IDLH).
• Employers who control civilian work at such facilities must assess oxygen levels, treat oxygen-deficient atmospheres as IDLH where applicable, and implement the respiratory protection and confined-space protections required by OSHA.

Yes — storing pre-charged units that together contain a Category 1 flammable gas on-site in one location can create a PSM-covered process if the aggregate refrigerant weight meets or exceeds the 10,000-pound threshold, as explained in the June 6, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 applies the PSM definition of "process" (which includes storage and on-site movement) and the Hazard Communication definition of Category 1 flammable gases to determine that aggregated pre-charged equipment can trigger coverage under 29 CFR 1910.119 when the refrigerant total in one location meets the threshold.
• Employers who store many pre-charged units should evaluate the total weight of flammable refrigerant on-site and, if the TQ is met or exceeded, comply with PSM requirements such as process hazard analysis, operating procedures, training, and mechanical integrity.

If a crane operator can be exposed to falling objects or overhead hazards, the employer must provide and require protective helmets that meet an applicable ANSI consensus standard, as explained in the June 6, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 references [29 CFR 1910.135(a)(1)] for the duty to require helmets when falling object hazards exist and specifies that helmets must meet one of the incorporated ANSI standards listed in [29 CFR 1910.135(b)(1)] (e.g., ANSI Z89.1 editions referenced in the standard).
• Employers should assess the crane operator's work area for overhead hazards, provide head protection where necessary, and select helmets certified to the ANSI editions incorporated by reference in [29 CFR 1910.135], as described in OSHA's interpretation.

No — simply stepping onto a low-slope roof from a portable ladder and walking to a work location 25 feet from the roof edge does not automatically require fall protection, but fall protection may be required once work begins, depending on distance from the edge and whether the work is temporary or infrequent, as explained in the June 6, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1 notes OSHA has no specific rule requiring fall protection for the act of stepping from a ladder onto a low-slope roof and walking to a location 25 feet from the edge.
• However, when work is performed within 6 feet of the roof edge a guardrail or other protection is required, and for work 15 feet or more from the edge employers must consider the temporary/infrequent nature of the work under 29 CFR 1910.28(b)(13)(iii) (discussed in the interpretation) to determine whether fall protection is required.

Mobile ladder stand platforms must meet the dimensional and guarding requirements set out for mobile ladder stands and platforms in 29 CFR 1910.23, as explained in the June 6, 2024 interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.

• The interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0 cites [29 CFR 1910.23(e)(1)(i)] requiring a step width of at least 16 inches and [1910.23(e)(2)(i)] requiring steps that are uniformly spaced with a rise not more than 10 inches and a tread depth of at least 7 inches, with the step stringer slope not more than 60 degrees from horizontal.
• The letter also explains handrail and guardrail thresholds: platforms under 4 feet typically do not require top/midrails, platforms 4–10 feet require handrails and midrails, and platforms over 10 feet must have guardrails and toeboards; and that top rails must withstand a 200-pound force per [29 CFR 1910.29(b)(3)] as cited in the interpretation.