ARTICLE
2 February 2026

DOL Follows Through On Use Of OSHA Standard Interpretation Letters

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In June 2025, the United States Department of Labor announced a planned expansion of its opinion letter program intended to increase compliance assistance across several agencies including OSHA.
United States Employment and HR
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In June 2025, the United States Department of Labor announced a planned expansion of its opinion letter program intended to increase compliance assistance across several agencies including OSHA. The initiative is intended to reinforce OSHA's commitment to offering valuable compliance assistance for workers, employers, and other stakeholders to help them comprehend how federal labor laws might apply to specific workplace situations. OSHA's letter of interpretation provide official explanations of the agency's requirements and how they apply to specific workplace situations and hazardous conditions raised by employers, employees, or other parties.

As stated by Deputy Labor Secretary Keith Sonderling, "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." Since June 2025, OSHA has issued 8 standard interpretations, which are available here.

These letters cover the following topics:

  • Recordability of workplace injuries resulting from personal rechargeable lithium-ion batteries
  • Clarification of "as free as practicable" lead contamination on surfaces
  • Electrical Busway Hot Swappable Plug-In Units
  • Whether the respiratory protection medical evaluation may consider factors beyond respirator use
  • 140 decibels (dB) impact/impulse policy under the noise standard
  • Red Light Therapy Wraps
  • Stair Angle and Tread Depth Requirements
  • Audiometric testing of a worker who may have a cochlear implant

These letters of interpretation are official, non-enforceable explanations that seek to clarify how certain standards might apply to specific conditions. They provide compliance guidance but do not create new obligations. Employers are reminded that the agency's position in these letters may also change over time and may be archived although still maintained for historical purposes.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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