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On December 10th, 2025, the U.S. Department of Labor's (DOL’s) Occupational Safety and Health Administration (OSHA) announced that it had issued seven letters of interpretation regarding workplace safety requirements. Specifically, the agency wants to ensure the consistent and transparent application of federal workplace safety and health standards. Although the letters of interpretation focus on specific sections of the national workforce (for example, one letter discusses permit required confined spaces), the overall concepts in the resources fall under the OSH Act and OSHA’s “General Duty Clause.” Indeed, both regulations apply to most employers in most workplaces. Earlier this month, OSHA issued a news release on the state of workplace safety enforcement. Specifically, the agency announced its standing and structure after the federal government shutdown.
What Is the Occupational Safety and Health Administration (OSHA)?
Overall, OSHA's mission is to assure America's workers have safe and healthful working conditions. Additionally, workplaces must be free from unlawful retaliation. According to the agency, it carries out its mission by:
- setting and enforcing workplace safety standards;
- enforcing anti-retaliation provisions of the OSH Act and other federal whistleblower laws;
- providing and supporting training, outreach, education, and assistance; and
- working collaboratively with state OSHA programs, ensuring that they are at least as effective as federal OSHA.
Finally, the OSH Act covers safety requirements for most private sector employers and their workers. The Act also covers some public sector employers and workers in the 50 states, certain territories, and federal jurisdictions.
What Is the General Duty Clause?
Altogether, as touched on earlier, the OSH Act sets and enforces workplace safety requirements and health standards. In doing so, it assures safe and healthful working conditions for working men and women. Notably, the “General Duty Clause” requires that all employers:
- shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; and
- shall comply with occupational safety and health standards promulgated under this Act.
In compliance with the OSH Act’s General Duty Clause and to avoid OSHA safety violations and costly litigation, employers should recognize and fix common workplace hazards. On a small scale, these common workplace hazards could include blocked exit routes, trip hazards, and unstable stacked items. They may also include the issues discussed in OSHA’s recently released letters of interpretation.
Overview of the Seven Letters of Interpretation
Generally, OSHA’s letters of interpretation provide official explanations of the agency’s safety requirements. Markedly, the letters explain how these rules apply to specific workplace situations and hazardous conditions posed by employers, employees, or other parties.
The December 2025 Letters of Interpretation address the following situations:
- Permit Required Confined Space: Whether the confined space standard requires employers to drain water from pipes before entering for repairs.
- Enforcement Stay of the COVID-19 Recordkeeping and Reporting Requirements under 29 CFR 1910.502: The enforcement status of OSHA’s COVID-19 reporting and recordkeeping requirements.
- Requirements Powered Industrial Truck Training Program Implementation: Whether an employee can demonstrate competence and knowledge in operating powered industrial trucks via a live-streamed session.
- Software Used to Generate OSHA Forms 300 and 300A: If companies are permitted to use their own software-generated documents to replace OSHA Form 300 and Form 300A.
- Engineering Controls Under the Benzene and 1,3-Butadiene Standards: Whether installing bellow valves, leak-proof, or double-seal valves qualifies as engineering controls.
- Audiometric Testing of Workers who Have Cochlear Implants: How audiometric testing applies to such employees.
- Stair Angle and Tread Depth Requirements: Whether stair and tread angles of specific dimensions comply with OSHA’s standard on stairways.
Employer Takeaways
In conclusion, as mentioned previously, although the examples used in the letters of interpretation involve specific workplaces and situations, OSHA laws and regulations apply to most businesses. Moreover, the release of these letters serves as a timely reminder to all employers to ensure they adhere to OSHA’s workplace safety requirements and rules.
To assist employers in maintaining compliance with various OSHA standards, WorkWise Compliance offers the following:
- OSHA General Industry Safety Training Program for Employees – This online, interactive eLearning program provides a clear, engaging, and easy-to-understand training experience that covers key OSHA principles, the General Duty Clause, reporting requirements, and employee protections. Designed specifically for OSHA general industry, the course ensures employees understand OSHA general industry standards and their rights under federal law.
