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🗞️ OSHA Announces Seven Letters of Interpretation as Part of Expanded Compliance Assistance Initiative

The Occupational Safety and Health Administration announced seven letters of interpretation on December 10, 2025, providing official guidance on federal workplace safety requirements ranging from confined space entry to audiometric testing for workers with cochlear implants.

onthelaborfront

onthelaborfront

— 3 min read
🗞️ OSHA Announces Seven Letters of Interpretation as Part of Expanded Compliance Assistance Initiative

On December 10, 2025, OSHA announced the release of seven letters of interpretation addressing key workplace safety and health requirements from the Department of Labor's opinion letter program, launched six months earlier. Deputy Secretary of Labor Keith Sonderling remarked that the letters provide "decisive guidance after gathering feedback from employers."

The seven letters, issued between January 3 and June 17, 2025 address workplace situations across multiple industries:

  1. Permit Required Confined Space (January 3, 2025) - Clarifies whether employers must drain water from pipes before entry when hazard assessments show no rupture or leak risk

  2. COVID-19 Recordkeeping Enforcement (February 5, 2025) - Explains the enforcement status of reporting and recordkeeping requirements under 29 CFR 1910.502

  3. Powered Industrial Truck Training (April 1, 2025) - Determines whether employees can demonstrate forklift competence via live-streamed sessions

  4. Alternative Recordkeeping Software (April 29, 2025) - Clarifies whether companies may use software-generated documents to replace official OSHA Forms 300 and 300A

  5. Engineering Controls for Hazardous Chemicals (May 8, 2025) - Addresses whether specific valve types qualify as engineering controls under Benzene and 1,3-Butadiene standards

  6. Audiometric Testing with Cochlear Implants (June 11, 2025) - Explains how hearing testing requirements apply to workers using cochlear implants

  7. Stair Angle and Tread Depth Requirements (June 17, 2025) - Determines whether specific stair dimensions comply with OSHA stairway standards

These letters of interpretation represent a marked shift in the Trump Administration's approach to workplace safety regulation. The opinion letter program, announced June 2, 2025, reversed a significant decline in such guidance documents during recent administrations. According to industry observers, the Wage and Hour Division issued 80 opinion letters during Trump's first term but only eight during the Biden administration, reflecting very different regulatory philosophies.

The program spans five DOL enforcement agencies: the Wage and Hour Division, OSHA, the Employee Benefits Security Administration, the Veterans' Employment and Training Service, and the Mine Safety and Health Administration. Each agency provides guidance in its area of expertise, with OSHA specifically issuing "letters of interpretation" that explain requirements without creating new employer obligations.

This compliance assistance approach aligns with the broader Trump Administration strategy of emphasizing voluntary compliance and reducing enforcement actions, contrasting with the Biden administration's more enforcement-focused approach. The letters provide authoritative interpretations that employers can rely on in good faith, potentially reducing litigation risk and promoting consistent application of safety standards.

The initiative comes amid significant regulatory changes at OSHA, including a regulatory freeze on new rules, potential budget reductions, and a shift toward cooperative programs over punitive enforcement. Despite this deregulatory direction, OSHA continues issuing interpretive guidance to help the regulated community understand existing requirements, particularly in areas involving emerging workplace challenges like remote training, technology integration, and accommodations for workers with disabilities.

The DOL has created a centralized landing page allowing users to explore past guidance and submit new requests, streamlining the process for obtaining official agency interpretations on specific workplace scenarios.

Key Points

  • Seven letters issued covering confined spaces, COVID-19 recordkeeping, forklift training, recordkeeping software, chemical engineering controls, hearing testing, and stair specifications
  • Part of broader initiative launched June 2025 across five DOL agencies to enhance compliance assistance and regulatory transparency
  • Reverses decline in opinion letters, with Trump's first term issuing 80 compared to Biden's eight from the Wage and Hour Division
  • Provides good faith reliance - employers can use these authoritative interpretations to demonstrate compliance efforts
  • Reflects policy shift toward voluntary compliance assistance rather than enforcement-focused approach of previous administration
  • Accessible online through new DOL landing page for exploring past guidance and submitting new requests

Primary Author: U.S. Department of Labor, Occupational Safety and Health Administration
Media Contacts: Kristen Knebel, Lorynn Holloway
Primary Source: U.S. Department of Labor, OSHA
Primary Source Link: https://www.dol.gov/newsroom/releases/osha/osha20251210

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