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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General contractor responsibility for hazard communication
An OSHA regional office asked when a general contractor may be cited for hazard communication violations at a construction site. OSHA said its multi-employer citation approach for hazard…
HAZWOPER and hazard communication training at waste generators
A worker asked what training a hazardous-materials generator must provide to employees who use, package, and move materials to a short-term storage area. OSHA said HAZWOPER depends on the operation,…
Hospital duties under HAZWOPER
An insurer asked how HAZWOPER applies to hospitals using outside fire departments. OSHA said hospitals are not categorically exempt: an internal hazardous-substance emergency, a hospital role in…
DOT vehicle-rule changes and an OSHA enforcement directive
An OSHA regional office asked to revise an enforcement directive after changes to federal motor-carrier rules. OSHA said the new DOT definition of a commercial motor vehicle would guide enforcement,…
HAZWOPER training for hazardous waste truck drivers
A trucking company asked whether drivers who transport hazardous waste but do not otherwise handle it need HAZWOPER training. OSHA said workers without exposure or potential exposure to hazards of…
Equivalent and site-specific hazardous-waste training for DOE workers
The Department of Energy asked OSHA to review draft guidance for hazardous-waste worker training. OSHA said equivalent training must still let employees safely perform their duties, including…
Type C soil assumption instead of trench soil testing
A lawyer asked whether an employer must test trench soil if it assumes the weakest Type C category and protects workers accordingly. OSHA said testing would be unnecessary if the employer meets all…
Correction of TCE flammability statement in earlier HAZWOPER letter
OSHA corrected its earlier statement that trichloroethylene had no fire hazard. It said TCE can burn and gave its explosive limits and flash point, but the earlier answer still held for the example…
HAZWOPER coverage for boilermakers in a clean Superfund site area
A contractor asked whether boilermakers rebuilding an incinerator in a clean area of a Superfund site needed HAZWOPER coverage. OSHA agreed the rule would not apply if there was no actual or…
Recording hearing loss and cumulative trauma on the OSHA 200 log
OSHA issued field guidance on when to record occupational hearing loss and upper-extremity cumulative trauma disorders on the OSHA 200 log. It set a hearing-shift threshold for citations and…
Site-specific HAZWOPER training for industrial emergency teams
A safety consultant asked whether generic HAZWOPER classes suffice for industrial emergency response teams. OSHA said general instruction can cover some topics, but training must also reflect each…
Grain elevator inspection program and OSHA fees
A senator asked about increased grain elevator inspections and alleged OSHA user fees. OSHA described a regional inspection emphasis program after full enforcement of the grain-handling standard…
Hazard communication for janitorial contractors
A janitorial company asked how the Hazard Communication Standard applies to mobile workforces and customers' chemicals. OSHA said exposed workers need usable hazard information and training, which…
HAZWOPER training for utility crews stopping leaks
A utility asked whether crews plugging a leaking transformer and searching for a gas leak were merely skilled support workers. OSHA said the emergency response plan must define roles and training…
Lockout and ignition-key control during truck maintenance
A laboratory asked whether a worker may adjust a truck from underneath while its engine is running. OSHA said that would present a hazard and violate the lockout and tagout rule. It said shutting…
Chain lanyards and safety nets for construction fall protection
A civil engineer asked whether chain could serve as a lanyard and whether general contractors must install safety nets. OSHA said its cited rule did not categorically prohibit chain, but discouraged…
Hazard warning labels on outer shipping containers
An OSHA regional office questioned whether outer packages containing hazardous chemical containers need separate Hazard Communication Standard warnings. OSHA reaffirmed that the standard's label…
Equivalent training and refreshers for TSD facility safety staff
An employer asked whether its safety professionals' previous training could count for occasional work at a permitted treatment, storage, and disposal facility. OSHA said equivalent experience may…
OSHA coverage of private workers in a state building
A state senator asked about workers in a termite-damaged state courthouse building. OSHA said federal law did not give it jurisdiction over the state employees there, but private-sector employees…
Certification and refresher training for HAZWOPER responders
An oil company asked how to train and certify its hazardous-materials responders. OSHA said its plan must cover an on-scene incident commander, annual refreshers, and hands-on training; qualified…
HAZWOPER training for ammonia refrigeration response
A cold-storage employer asked what HAZWOPER training was needed for possible ammonia releases. OSHA said an exemption from some waste-facility provisions did not automatically remove…
Measuring minimum illumination at construction sites
A construction office asked how to understand the foot-candle unit used in OSHA's site lighting rule. OSHA said illumination varies with the light source and surroundings, so the level at the work…
Hazard communication for chemicals in office humidifiers
An engineer asked whether the Hazard Communication Standard covers chemicals added to office humidification systems. OSHA said maintenance staff and others who handle or store the chemicals may be…
Pesticide containers and hazard communication labels
An OSHA regional office asked whether an unlabeled pesticide container could be cited under the Hazard Communication Standard. OSHA said a proven EPA-regulated pesticide label issue belongs with…
Carcinogen warnings on fibrous glass product labels
A requester questioned cancer warnings on fibrous glass products. OSHA said its 1991 review of scientific literature supported an appropriate label warning that fibrous glass may cause lung cancer…
Posting the OSHA workplace notice
A congressman asked whether a constituent had to display workplace posters mentioned in business mail. OSHA said its regulation requires every covered employer to post the official OSHA notice…
Correction to UCX audit compliance guidance
ETA warned state unemployment agencies that an OMB audit supplement used outdated eligibility criteria for unemployment compensation for former service members. The letter printed the criteria ETA…
Disaster unemployment benefit amounts, April to June 1991
ETA supplied state average weekly benefit amounts to use when calculating disaster unemployment assistance for major disasters from April through June 1991. Its attachment listed each jurisdiction's…
Employer inquiries about the Multiple Worksite Report
ETA alerted state unemployment insurance tax offices that employers might ask them about the new quarterly Multiple Worksite Report. State administrators were to equip tax staff to answer general…
Shielding of drive lines on pivotal sprinklers and an interpretation of the words "guarded by location".
A sprinkler operator asked whether drive lines on pivotal irrigation systems needed shielding and what OSHA meant by "guarded by location." OSHA said the shafts could be treated as guarded by…
Implementation of a comprehensive chemical hygiene plan for lab operations
A law firm asked whether an employer could use one comprehensive chemical hygiene plan for all laboratory operations and satisfy OSHA’s laboratory and hazard communication requirements. OSHA said…
Rollover protective structures for material handling equipment
A law firm asked whether trenchers and similar crawler equipment needed rollover protective structures under OSHA’s construction standard. OSHA said the depicted trenchers required ROPS when used in…
Time and resources needed to comply with Lab Standard is justifiable
A member of Congress asked OSHA to respond to a constituent’s concern that the Laboratory Standard required too much time and money. OSHA said the rule was necessary and feasible, allowed…
Extension Cords Connected to Permanent Wiring of a Construction Site Building
A Virginia OSHA official asked whether extension cords connected to a construction building’s permanent wiring counted as temporary wiring and needed protection. OSHA answered yes to both questions:…
Procedures for release of 1990 unemployment insurance quality-control data
ETA directed state unemployment agencies to freeze their 1990 quality-control data on April 26, reconcile annual reports, and release their results by June 28, 1991. It specified report formats,…
Definition of Reasonable Diligence as stated in 1910.1096(d)(1).
A senator asked when an employer’s knowledge of elevated radon in a surrounding area created a duty to survey the workplace. OSHA said the answer depended on the facts and was not triggered by a…
Retesting when audiogram shows employees have suffered STS shift
An occupational audiologist asked how soon an employer must retest an employee after an annual audiogram shows a standard threshold shift. OSHA said the retest must be completed within 30 calendar…
Self-centering controls will be required on overhead bridge and container handling gantry cranes only.
An engineer asked which marine-terminal cranes had to use self-centering operating controls. OSHA said 29 CFR 1917.45(f)(1)(ii) applied only to overhead bridge and container handling gantry cranes,…
Acceptable use of the presence sensing device
A mill operator asked whether a presence-sensing light curtain could serve as a safety control under OSHA’s mill-guarding rule. OSHA said a tested and listed light barrier could replace or support…
Work permits in lockout/tagout standard requirements
A chemical company asked whether work permits could satisfy parts of OSHA’s lockout/tagout procedure requirements. OSHA said a documented generic procedure could be supplemented by required permits…
Use of Blood Carboxyhemoglobin to Document Employee Exposure to Carbon Monoxide
An OSHA regional office asked whether blood carboxyhemoglobin levels could establish workers’ carbon monoxide exposure when air measurements were unavailable. OSHA said the blood result could not…
Questions and Answers on the New Penalty System.
OSHA sent regional offices answers to staff questions about its then-new penalty system. The answers covered informal conferences, good-faith reductions, recordkeeping penalties, and how older…
Clarification of OSHA Instruction CPL 2.45B CH-1.
OSHA clarified internal inspection instructions after old references to records-only inspections remained in its field manual. It said programmed safety inspections from the register should be…
Compliance with 1910.147 using the new Block-Out safety product line.
A manufacturer asked whether its lockout products met OSHA’s hazardous-energy control standard. OSHA said the submitted information was insufficient for a complete compliance decision, pointed to…
Separate line for a full body harness
An engineer asked whether workers raised in body harnesses by a winch needed a separate safety line and whether the winch line could protect someone climbing a fixed ladder. OSHA said a worker…
MSDS requirements for scrap materials
A consultant for scrap recyclers asked OSHA to review hazard determinations and material safety data sheets for scrap commodities. OSHA said hazard information had to reach all downstream employers…
Jurisdictional Issue - Southwest Transportation.
An OSHA regional office asked which agency handled a truck-loading safety dispute. OSHA said loading and unloading at destination points fell within its jurisdiction, while readjusting and securing…
Non-finishing spraying of contact cement to wood or to laminae
A building contractors’ association asked whether OSHA’s spray-finishing standard covered spraying contact cement on wood and laminate for bonding rather than finishing. OSHA said the operation fell…
Occupational noise exposure limits
An equipment company asked whether a telephone product standard allowed sound levels above OSHA’s workplace noise limits. OSHA said some product-standard levels exceeded its continuous-noise limit,…
Clarification of approval requirements for equipment to classify underground construction operations as potentially gassy
An OSHA regional office asked how testing-laboratory approval rules apply to underground construction equipment. OSHA said the general-industry NRTL rule did not govern construction, described how…
The Standards do not exclude equipments by weight of the machine for rollover protective structure.
An equipment supplier asked whether a small excavator could avoid rollover protective structures because it weighed less than 700 kilograms. OSHA said its construction standards did not exclude the…
Issuing OSHA Form 72's for Defective Gear Found Aboard Vessels
An OSHA regional office proposed using Form 72 to report defective cargo gear aboard vessels. OSHA said existing cargo-gear registers and certification rules already provided notice, so requiring…
Information on Robotics, Presence Sensing Devices, Ergonomics, and Hand Speed Criteria
An OSHA office summarized material for agency recommendations on machine guarding, robotics, and ergonomics. It said a presence-sensing device could be considered under a de minimis enforcement…
The point of operation and rotating part hazards related to vertical food mixers in bakeries and restaurants are covered by the Occupational Safety and Health Administration standards.
An engineer asked OSHA what action it would take on hazards from vertical food mixers. OSHA said its machine-guarding rules covered mixer points of operation and rotating parts and that it had…
Enforcement of the Hazard Communication Standard as it relates to "vegetable oil mist"
A cotton-industry representative questioned label and material safety data sheet duties for vegetable oil mist under OSHA’s Hazard Communication Standard. OSHA said a substance with a specific OSHA…
Automatic return attachments on radial saws
A saw manufacturer asked whether OSHA required automatic return attachments on radial saws. OSHA said its rule required the cutting head to return gently to the starting position when released, but…
Employees who design and engineer hazardous waste facilities and their coverage under 1910.120.
An engineering company asked whether its employees needed HAZWOPER training when they visited hazardous waste incinerators for design work or tests. OSHA said regular duties in permitted areas could…
The obligations and responsibilities of machine manufacturers under the lockout/tagout standard.
A machine builder asked whether OSHA’s lockout/tagout standard applied to manufacturers as well as machine owners. OSHA said new or substantially modified equipment needed energy-isolating devices…
Immigration Act amendment to unemployment eligibility rules
ETA explained that the Immigration Act of 1990 removed an obsolete Immigration and Nationality Act citation from the federal unemployment tax law's rule on work performed by noncitizens. It said…
A rescue team is required during all phases of underground construction operations in a tunnel.
A construction safety superintendent asked whether tunnel rescue teams were still needed after the primary structural phase. OSHA said 29 CFR 1926.800(g)(5) required a rescue team throughout all…
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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.