OSHA Summarizes 2025 Interpretation Letters: Key Compliance Updates  

• Permit-Required Confined Spaces: Per 29 CFR 1910.146(c)(1), covered employers are required to identify permit-required confined spaces. The interpretation letter applies to work being done on pipes that carry water, steam, and other fluids, valves, flanges, and other parts. Employers must assess confined spaces to determine whether a permit is required to authorize access and isolate the space prior to entry. Isolation is not required if pipes do not terminate in the confined space and there is no potential for ruptures or leaks that could cause injuries. 

• Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502: OSHA has ceased COVID-19 recordkeeping and reporting requirements; it will not cite employers for violations of requirements to maintain a COVID-19 log under 29 CFR 1910.502(q)(2)(ii) and (q)(3)(ii)-(iv), or to report COVID-19 fatalities and hospitalizations under 29 CFR 1910.502(r).  

• Requirements for Powered Industrial Truck Training Program Implementation: In accordance with 29 CFR 1910.178(l)(2)(i)(A), trainees may only operate a powered industrial truck under the in-person, direct supervision of a person with the knowledge, training, and experience to train operators and evaluate their competence. The employer must have a process to determine successful completion of training, including classroom, practical training, and demonstration elements.  

• Software used to generate equivalent OSHA Forms 300 and 300A: A company may generate forms 300 and 300A using its own software system. Sections 1904.29(b)(4) and (b)(5) allow employers to record required injury and illness information on electronic media in various file formats, e.g., Excel, CSV, or on their own paper forms provided that they are equivalent to the OSHA forms they replace.  

• Engineering controls under the Benzene and 1,3-Butadiene standards: The installation of bellow valves, leak-proof, or double-seal valves are considered forms of engineering controls under these standards. Employers may implement a combination of engineering controls and work practices to reduce and maintain employee exposure at or below permissible exposure limits.  

• Audiometric testing of a worker who may have a cochlear implant: After receiving instructions, an employee with an implanted cochlear device should turn it off during a hearing test. Audiometric testing requirements in 29 CFR 1910.95 do not include a specific exception for hearing-impaired employees with cochlear implants. Hearing tests for people with an implant may differ from those used for acoustic hearing. 

• Stair Angle and Tread Depth Requirements: Under 29 CFR 1910.25(c)(3), stairs are required to have a 9.5-inch minimum tread depth to help prevent slips and falls. The standard requires tread depth to be measured horizontally between the vertical planes of the foremost projection of adjacent treads, and at a right angle to the tread’s leading edge, excluding beveled or rounded tread surfaces that slope more than 20 degrees. 

Visit OSHA’s Letters of Interpretation webpage to review previous guidance and submit requests.