Federal Labor Guidance
Free plain-English summaries of opinion letters, administrative policies, and interpretive notices from the U.S. Department of Labor, with the current status and the official source on every page.
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Historical OSHA 200 treatment criteria for cumulative trauma
OSHA explained its then-current OSHA 200 criteria for cumulative trauma disorders, including when symptoms plus treatment or lost workdays made a case recordable. It treated immobilizing casts or…
HAZWOPER coverage of home heating oil distributors
A consultant asked whether a home heating oil distributor could fall under HAZWOPER. OSHA said a company whose employees respond to a hazardous-substance emergency must meet paragraph (q), while one…
Unemployment fund cash management under the CMIA
ETA explained how the Cash Management Improvement Act of 1990 would affect state unemployment funds. Pending new Treasury rules and performance measures, it told state unemployment insurance…
Combined-wage claims and interstate wage-transfer procedures
ETA answered 30 state agency questions about unemployment claims that combine employment or wages from more than one state. It clarified when a worker can choose or withdraw such a claim, when…
Child support identification on unemployment claim forms
ETA said a state unemployment agency need not ask about child support obligations on its intrastate initial claim form when its agreement with the child support agency provides another way to…
HAZWOPER training for spill response and cleanup roles
An environmental services company asked what HAZWOPER training different spill workers needed. OSHA said stopping a release at its source calls for technician-level training, while defensive…
Experience and certification for HAZWOPER incident commanders
A consultant asked whether professional experience qualified him as an on-scene HAZWOPER incident commander. OSHA said prior education and experience can count toward some training, but the employer…
Apprenticeship credit toward HAZWOPER site training
An apprentice asked whether a past program counted toward HAZWOPER initial training. OSHA said the employer could compare documented instruction with the required objectives, but supervised field…
Engineer experience as equivalent HAZWOPER training
An employer asked whether licensed engineers with plant experience could count as equivalently trained under HAZWOPER. OSHA said academic and work experience can count only when all required safety…
Hazard data sheets for tire-recycling rubber dust (C directive)
OSHA answered whether a tire recapper selling rubber dust needed a hazard label and material safety data sheet. It said the company should review available evidence for hazards in the dust it…
Hazard data sheets for tire-recycling rubber dust (D directive)
OSHA answered whether a tire recapper selling rubber dust needed a hazard label and material safety data sheet. It said the company should review available evidence for hazards in the dust it…
Hazard communication for workplace consumer-product use
A regional office asked when workplace use of household cleaning products falls outside the Hazard Communication Standard’s consumer-product exemption. OSHA said the employer must assess whether…
Equivalent HAZWOPER training for tank-removal subcontractors
An environmental company asked whether experienced underground storage tank subcontractors could avoid repeating the initial HAZWOPER course. OSHA said equivalent documented experience and training…
Safety responsibility for leased employees
An employee leasing company asked which joint employer would be responsible for workplace safety and citations. OSHA said it evaluates the relationship case by case, with direct day-to-day…
Historical Section 17 settlement designation guidance
OSHA told its regional administrators when a post-settlement Section 17 designation could replace a willful or repeated classification while retaining penalties and securing abatement or other…
Quality control program improvement studies
ETA told state unemployment agencies when they could use quality control staff for program improvement studies. A state needed advance national office approval to reduce its required quality control…
HAZWOPER response coverage for transporters and waste sites
A consultant asked when hazardous-materials drivers become emergency responders and how HAZWOPER applies at treatment and storage sites. OSHA said active participation in an emergency response…
Motor starter controls and energy isolation for conveyor servicing
An OSHA regional office asked whether keyed motor starter controls could isolate power to conveyors during package clearing. OSHA said starter circuits and stop buttons are control devices, not…
Acceptable flotation devices for commercial work
A manufacturer asked whether a Coast Guard approved life belt could satisfy OSHA requirements for workers who need flotation devices. OSHA said the device's approval type and marked use restrictions…
Railroad operating conditions and the FRA's authority
A union representative raised concerns about the working environment of train operating employees. OSHA said the Occupational Safety and Health Act generally excludes working conditions already…
Disaster unemployment benefit amounts, July to September 1991
ETA supplied state average weekly benefit amounts to use when calculating disaster unemployment assistance for major disasters from July through September 1991. Its attachment listed each…
Annual inspections of lockout and tagout procedures
An employer asked how to conduct periodic inspections under the lockout and tagout rule. OSHA said an authorized employee other than those using the procedure must inspect it at least annually,…
Machine guarding and lockout during meatpacking cleanup
A requester asked whether meatpacking machinery needs guarding or lockout during cleaning and sanitizing. OSHA said employees need effective safeguards and that lockout applies when servicing…
Point of operation guarding on a tire chain link device
A manufacturer asked whether a tool for replacing tire chain links complied with OSHA rules. OSHA said the information was insufficient for a compliance determination and identified a possible…
One wheel chock during trailer loading
A manufacturer asked whether the plural word “chocks” requires more than one wheel chock during trailer loading with powered industrial trucks. OSHA said one chock can satisfy the rule if it…
Traffic barricades and signaling on highway construction jobs
An OSHA memorandum explained which construction standards apply to traffic control on highway projects. It assigned barricade design and application to section 1926.202 and missing or insufficient…
First aid support for hazardous substance emergency response
An Oregon safety official asked what level of first aid training HAZWOPER requires for support personnel standing by at an emergency response. OSHA said the two training levels proposed in the…
HAZWOPER training for petroleum releases and cleanup
A consultant asked how HAZWOPER applies to petroleum spills and cleanup workers in many roles. OSHA distinguished emergency response, hazardous waste site cleanup, and treatment or disposal…
Fall protection and OSHA coverage for a foreign employer's U.S. work
A Canadian requester asked about fall protection while climbing and working on a steel lattice structure and about OSHA's reach. OSHA said employers must provide appropriate fall protection, but…
Halon 1301 fire and explosion suppression systems
An OSHA regional office sought guidance on workplace Halon 1301 systems used for both fire and explosion suppression. OSHA said section 1910.162 applies to fire suppression, while OSHA standards do…
Wire rope perimeter guards on open-sided construction floors
An insurer asked whether wire rope perimeter guarding could protect open-sided construction floors. OSHA said an employer using wire rope instead of specified guard methods must show equivalent…
Masonry wall support and a variance request
A masonry contractor sought a permanent variance from construction rules for limited access zones and wall bracing. OSHA said each job requires an evaluation of whether walls are adequately…
Guarding needles, belts, and wheels on industrial sewing machines
An industry association asked how machine-guarding rules apply to heavy duty sewing machines. OSHA described a barrier around the needle as the immediate way to address hand contact, but said…
De minimis treatment of spray booth metal deflector provision
A consultant asked whether OSHA's spray booth metal deflector rule still applied and what hazard it addressed. OSHA said the text remained in its standard, but after reviewing a later NFPA revision…
Welding fume and iron oxide exposure limits
An OSHA regional office asked whether to apply the welding-fume exposure limit or the iron-oxide-fume limit when welding iron. OSHA said the welding-fume limit applied to welding iron, mild steel,…
Firefighter protective clothing for aircraft rescue operations
A firefighters' union questioned OSHA statements about protective clothing for aircraft rescue operations. OSHA said it evaluates the expected hazards and whether gear provides at least equivalent…
Protecting flexible cords in tunnel shafts
An OSHA area office asked about type SO flexible electrical cords in tunnel shafts. OSHA said the cord's own insulation does not protect against heavy-object damage such as a muck bucket strike, so…
Hands-on fire extinguisher training without live fire
A requester asked whether employees must start and extinguish an actual fire to meet hands-on training requirements. OSHA said a live fire is not necessary; practical training should at least…
Training hours for post-emergency beach cleanup crews
An OSHA memorandum addressed reports that beach cleanup crews always needed 24 hours of HAZWOPER training. OSHA said that amount might be appropriate for some operations, while fewer hours could be…
Oil spill beach cleanup versus emergency response training
An OSHA regional office asked about training for beach cleanup crews and state-plan requirements. OSHA said shore cleanup is typically post-emergency response, while oil containment on water may…
Fiberglass product warning label under hazard communication
A manufacturer asked OSHA to review warning language for products containing fiberglass wool. OSHA said the submitted label's cancer and irritation warnings appeared to meet the intent of the Hazard…
Safety stands and lockout for raised buses
A supplier asked whether bus maintenance facilities must use stands when employees work beneath raised buses. OSHA said its lockout and tagout rule addresses the falling-bus hazard: a portable hoist…
OSHA coverage and hazards in public health services
An OSHA office answered questions about coverage and hazards in health and medical services. It said federal OSHA did not cover state and local public employees, while approved state plans could…
Natural disasters and HAZWOPER emergency planning
An OSHA regional office asked whether a natural event such as a tornado can trigger HAZWOPER emergency planning. OSHA said an employer in a hazard-prone area should anticipate whether such an event…
Employer payment and certificates for HAZWOPER training
OSHA answered whether employers may charge employees for 40-hour hazardous waste training or recover its cost through payroll deductions. It said training required by section 1910.120 must be free…
Space requirements for mobile migrant-worker housing
A portable housing developer asked whether OSHA's temporary labor camp floor-space rule applies to mobile units. OSHA said mobility creates no exception: the 100-square-foot-per-person requirement…
OSHA coverage of municipal workers and city contractors
An engineering firm raised concerns about safety on a city project in Ohio. OSHA said state and local government employees were outside federal OSHA coverage unless an approved state plan covered…
Documentation of unemployment insurance field audits
ETA clarified the documentation that state unemployment insurance field auditors should keep. Completed audit files needed enough evidence to support findings about payments for services, including…
Rebar impalement protection and scaffold midrails
A safety adviser asked about exposed reinforcing steel and a proposed scaffold guardrail design. OSHA said its concrete and masonry rule protects against falls into both vertical and horizontal…
Awareness-level HAZWOPER training for police officers
A police department asked how many hours officers need for first-responder awareness training under HAZWOPER. OSHA agreed that awareness-level training was a minimum for officers who may respond to…
HAZWOPER coverage of coal fires and ammonia leak response
An OSHA regional office asked whether HAZWOPER covers a coal fire and an ammonia leak involving a refrigeration contractor. OSHA said fires involving releases of materials classified as hazardous…
Custody and confidentiality of employee medical records
A physician asked how medical surveillance records should be kept under OSHA standards. OSHA said the employer must establish and maintain each covered employee's record, although a physician may…
Electrical safety rules at plants that generate power
An OSHA regional office asked whether electrical safety work-practice rules apply at sugar beet and sawmills that generate some power. OSHA said utilization equipment remained covered, while…
HAZWOPER training for emergency medical personnel
An emergency medical service asked what HAZWOPER training its personnel needed at hazardous-substance incidents. OSHA said duties control the level: treating fully decontaminated patients outside…
Approval of extension cord assemblies by a testing laboratory
An OSHA regional memorandum addressed extension cords used at workplaces, especially construction sites. It said the complete cord set must be approved by a nationally recognized testing laboratory;…
HAZWOPER and emergency response involving radioactive materials
A state health physicist asked whether HAZWOPER covers emergency response involving radioactive waste. OSHA said the Nuclear Regulatory Commission governs licensed radioactive material inside…
Equivalent HAZWOPER training and site experience
An engineering firm asked whether experienced hazardous-waste workers could be certified as equivalently trained and receive in-house training certificates. OSHA said employers may use documented…
Hazard communication for hospital drugs and medications
A federal hospital agency asked when OSHA's Hazard Communication Standard covers employees preparing or administering medications. OSHA said tablets intended to be crushed before administration are…
TRA and disaster claims filed for incapacitated or deceased workers
ETA changed its earlier interpretation and allowed an authorized legal representative to file trade readjustment allowance or disaster unemployment assistance claims for an incapacitated or deceased…
Recapping used needles and sharps disposal
A clinic asked whether needles could be recapped when changing needles after drawing medication. OSHA said used needles generally should go into sharps containers without recapping, but if recapping…
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These are official interpretive documents from the U.S. Department of Labor: opinion letters answering questions from employers and workers, administrative policies, and interpretive notices. They show how the agency applies wage-and-hour and workplace law to real situations, but they are guidance, not statutes or court decisions, and the agency can supersede or withdraw them. Every page above shows the document's current status, when that status was last verified, and a link to the official source.