We are attempting to respond as expediently as possible, taking into consideration the need for a thorough and responsive reply. We regret that due to increasing requests for letters of interpretation, it will take up to 90 days for us to respond to you. The two referenced letters are in conflict with each other in interpreting the standard. Individual companies frequently request guidance from their association concerning compliance with OSHA standards. To date, the national association has not been informed that the 1986 guidance has been changed, assuming the 1993 letter represents OSHA's current position.
Clarification is requested concerning which letter is the correct interpretation.