1910 Subpart H
OSHA's legal authority for these standards comes from the Occupational Safety and Health Act of 1970 (Sections 4, 6, and 8) and the Secretary of Labor's Orders, as well as 29 CFR part 1911. See 1910 Subpart H for the Authority statement that lists the statutory bases (29 U.S.C. 653, 655, 657), the Secretary of Labor's Orders, and cross-references to 29 CFR part 1911.
Yes. Storing pre-charged air conditioners or heat pumps that together contain a Category 1 flammable gas on site in one location meets the definition of a covered "process" under 1910.119 because the standard defines a process to include storage and on-site movement of highly hazardous chemicals, and the PSM threshold applies when the aggregate amount on site in one location meets or exceeds the threshold quantity. See OSHA's interpretation on PSM flammable gas aggregation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 for examples and reasoning.
No—OSHA announced an immediate enforcement stay of the COVID-19 recordkeeping and reporting requirements under 29 CFR 1910.502, so it will not cite employers for failing to establish or maintain the COVID-19 log or for reporting COVID-19 fatalities and hospitalizations under that rule until further notice. See OSHA's enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 for details. Employers should still follow recordkeeping requirements in 29 CFR part 1904.
OSHA allows temporary removal of lockout/tagout devices and re-energization only for the limited time needed to test or position machinery, but employers must follow a required sequence and provide effective employee protection during those energized periods. See OSHA's interpretation on the minor servicing exception and temporary re-energization procedures at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-21 which explains the steps and protections required under the [1910.147] standard (Control of Hazardous Energy). Employers must clear tools and materials, remove employees from the danger area, remove devices as specified, energize for testing with protections in place, then de-energize and reapply energy control devices when testing is complete.
Yes—if a crane operator is exposed to overhead hazards that could injure the head (for example, from falling objects while lifting loads), the employer must ensure the operator wears head protection that meets the applicable ANSI consensus standards. OSHA explains this in its interpretation on head protection for crane operators at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2 and the head protection requirement is found in the head protection standard referenced by OSHA at 1910. Employers must assess the workplace per 1910.132 and provide helmets that comply with the incorporated ANSI standards.
Measure the stair width between vertical barriers; handrails are not considered vertical barriers and therefore do not reduce the required minimum width. OSHA's interpretation on stair width measurement clarifies that the minimum 22-inch requirement for standard stairs is measured between vertical barriers and that a handrail is not treated as a barrier: see https://www.osha.gov/laws-regs/standardinterpretations/2024-10-17 and refer to 1910 for the related stair requirements.
No—simply stepping from a portable ladder onto a low-slope roof and walking to a work area 25 feet from the edge does not automatically require fall protection, but fall protection may be required for the work performed on the roof depending on the distance to the edge and whether the work is infrequent and temporary. OSHA's interpretation on fall protection for low-slope roofs gives this guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-1 and explains how [1910.28] applies to work performed less than or greater than specified distances from the roof edge.
Mobile ladder stand platforms must have steps that are uniformly spaced with a rise not more than 10 inches, a tread depth of at least 7 inches, and a step width of at least 16 inches; platform and handrail requirements depend on platform height. OSHA's interpretation answering mobile ladder stand questions provides the dimensional and railing requirements and cites the applicable ladder/platform rules at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0 (see the explanation referring to the ladder and mobile ladder stand platform rules in [1910]).
Yes—the PSM standard refers to the Hazard Communication definitions in [1910.1200] (as interpreted in OSHA guidance) to identify Category 1 flammable gases, so gases meeting the Category 1 criteria in the Hazard Communication rules are treated as covered flammable gases for PSM threshold determinations. OSHA explains this linkage and application in its PSM flammable gas aggregation interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06 and by reference to 1910.119.
No—OSHA letters of interpretation explain how OSHA understands and will apply OSHA requirements, but they do not create new obligations or change the standards; State Plan states remain required to have programs at least as effective as Federal OSHA and may have more stringent rules. OSHA makes this clear in multiple interpretations (for example, see the rim wheel servicing letter at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01), and the Authority statement at 1910 Subpart H explains the regulatory basis.
If the remediation work involves asbestos-containing building materials, OSHA expects those activities to be covered by the construction asbestos standard, 29 CFR 1926.1101, rather than the general industry asbestos standard. OSHA explains this point in the asbestos remediation protocols interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and references that construction-related remediation activities involving ACBM are subject to [29 CFR 1926.1101].
Yes—civilian employees (including contractor employees) working on DoD facilities are covered by OSHA standards when performing work that is not uniquely military, and they must comply with OSHA's Respiratory Protection requirements for oxygen-deficient atmospheres. OSHA's interpretation addressing HVAC and oxygen-deficient atmospheres explains coverage and applicability and can be found at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16; that interpretation also references the definition of "oxygen-deficient atmosphere" used in OSHA's respiratory protection policies.
OSHA indicates that while C-type light truck tires are similar to LT tires, they are not automatically out of scope; failure to comply with portions of 29 CFR 1910.177 related to servicing C-type tires may be treated as a de minimis condition depending on whether installation, servicing methods, and equipment are substantially similar. See OSHA's interpretation on the scope of rim wheel servicing at https://www.osha.gov/laws-regs/standardinterpretations/2024-08-01 for the full explanation.
No—mobile ladder stand platforms with a platform height of less than 4 feet (48 inches) do not require a top rail or midrail; the requirement for handrails and midrails begins for platforms 4 to 10 feet high, and full guardrails and toeboards are required above 10 feet. OSHA's mobile ladder stand interpretation provides these thresholds and details at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0.
Guardrail systems must be capable of withstanding, without failure, a force of at least 200 pounds applied in a downward or outward direction within 2 inches of the top edge at any point along the top rail; this performance requirement is discussed in OSHA's mobile ladder stand interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-0 and is tied to the general guardrail performance rule referenced by OSHA under [1910].
In addition to the Occupational Safety and Health Act, OSHA notes that 1910.119 was also issued under Section 304 of the Clean Air Act Amendments of 1990 (Pub. L. 101-549), as noted in the Authority statement for 1910 Subpart H. This cross-reference is included in the Authority text that accompanies the Subpart H standards.