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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Georgia automobile dealers welfare plan as a MEWA
The request asked whether an automobile dealers association’s welfare plan was a MEWA subject to state insurance oversight. EBSA found it covered workers of separate employers and was a MEWA,…
Kansas Society of Architects benefit trust as a MEWA
Kansas regulators asked whether an architects association’s benefit trust could claim ERISA protection from state insurance oversight. EBSA found that the trust served employees of separate…
Workplace asbestos exposure and smoking restrictions
An asbestos consultant asked whether smoking had to be barred in buildings with low measured asbestos levels. OSHA said the smoking restriction applied when asbestos exposure came from workplace…
First aid supplies for retail stores
A retailer asked what first aid supplies its stores needed. OSHA said the cited standard did not require supplies if an infirmary, clinic, or hospital was nearby; otherwise a physician chosen by the…
Employer citations at construction multi-employer worksites
A safety society asked how a construction rule applied at multi-employer worksites. OSHA said that rule's Subpart B had no direct significance for enforcement under the OSH Act, but its field policy…
Negative pressure glovebags for asbestos removal
An industrial hygienist questioned negative pressure glovebags for asbestos removal. OSHA said the method could meet the intent of a negative pressure enclosure for limited work when other asbestos…
Alternative asbestos removal system and enclosure requirements
A supplier asked whether its asbestos pipe-insulation removal system could meet OSHA's enclosure requirements. OSHA said it did not certify equipment, but the described method could meet the rule's…
Transportation Department jurisdiction over pipeline odorant tanks
A supplier asked whether OSHA could regulate diking and placarding of odorant storage tanks at pipeline facilities. OSHA said Transportation Department regulation of those tanks precluded OSHA…
Safety sheet delivery by beauty supply distributors
A senator forwarded a beauty supply distributor's concerns about material safety data sheet delivery. OSHA said distributors generally had to send a sheet with the initial shipment and when it was…
Form 1099-G reporting of 1990 unemployment benefits
ETA instructed state unemployment agencies on Form 1099-G notices for benefits paid in calendar year 1990. It addressed substitute statements, the optional treatment of payments under $10, reporting…
Lead exposure controls at non-ferrous foundries
A state workers' compensation official asked about lead exposure control requirements for non-ferrous foundries. OSHA said employers could then use controls including respirators to meet the 50…
Asbestos bagging station as a regulated area
A contractor asked whether a trailer bagging station connected to asbestos work needed the same enclosure and decontamination setup as the removal area. OSHA said bagging was separate from removal…
Hazardous materials technician and incident commander training
A state emergency management office proposed combining an eight hour responder course with sixteen additional hours for technicians and incident commanders. OSHA said the standard required 24 hours…
Sharps disposal container review and OSHA endorsement
A medical waste container maker asked OSHA to assess its sharps disposal system. OSHA said it did not approve or endorse devices; the described system appeared to meet then-current requirements for…
Quality control and nonroutine tests under the laboratory standard
A manufacturer asked whether its laboratories performing standardized production quality control tests had to follow OSHA's laboratory standard. OSHA said those routine tests were outside the…
Formaldehyde medical screening and paid time
A garment workers' union asked whether low formaldehyde air readings excused medical screening and whether workers could lose pay for it. OSHA said the 0.1 ppm language was guidance, not an…
Georgia Health Care Association trust as a MEWA
The request asked whether the Georgia Health Care Association’s employee benefit trust could avoid state insurance regulation under ERISA. EBSA found it served workers of separate employers and was…
Consumer Association medical trust as a MEWA
The request asked whether the Consumer Association for Security and Health medical benefit trust was a MEWA. EBSA found it provided benefits for employees of separate employers, making it a MEWA…
Virginia automobile dealers benefit program as a MEWA
The request asked whether an automobile dealers association’s benefit program was a MEWA. EBSA found that it served employees of separate dealers and was a MEWA open to state insurance regulation,…
Independent Contractors Association welfare trust as a MEWA
The request asked whether an independent contractors association’s welfare trust was a MEWA. EBSA found that its benefits reached employees of separate employers and that the trust was a MEWA…
Limits of packaged hazard communication training
A requester asked OSHA to review a commercial hazard communication training package. OSHA said it did not approve training materials and that compliance depended on covering required topics,…
Gas pipeline excavations and overlapping DOT rules
OSHA told its regional offices that two excavation safety provisions could not be enforced against natural gas transmission and distribution employers where Transportation Department rules covered…
HAZWOPER coverage for underground storage tank work
A regional office asked when work on underground storage tanks fell under HAZWOPER. OSHA said cleanup, corrective action, or emergency response provisions could apply, and listed conditions such as…
State plan hepatitis B vaccination costs in 1990
An OSHA office asked whether South Carolina's state plan could be required to make employers pay for hepatitis B vaccination and follow-up. OSHA said it could not require the state to enforce a…
When a spill triggers HAZWOPER emergency response
An employer asked when a hazardous substance spill becomes a HAZWOPER emergency. OSHA said the amount spilled alone was not decisive; the material, location, danger, and need for immediate action…
HAZWOPER training for workers in clean site areas
A worker safety fund asked whether construction workers in clean parts of a designated waste site needed HAZWOPER training. OSHA said workers outside contaminated areas who did not enter hazardous…
Field sanitation standard and reforestation hand labor
A regional office asked why OSHA applied its agricultural field sanitation rule to reforestation. OSHA said reforestation involving hand labor fit the standard's coverage, citing its similarity to…
Meaning of high acute toxicity in laboratory rules
A regional office asked what the laboratory standard meant by substances with a high degree of acute toxicity. OSHA said these were highly toxic or toxic substances under its hazard communication…
HAZWOPER emergency response at food and chemical plants
A food and chemical company asked whether HAZWOPER emergency response rules applied at its plants. OSHA said the emergency response section applied to potential emergencies involving ammonia…
Recording cumulative trauma disorders in meatpacking
A union asked when meatpacking employers should record cumulative trauma disorders. OSHA said a second visit for subjective symptoms alone did not establish a recordable illness; additional medical…
Labels for fabricated hazardous chemical products
A fabricator asked whether it could attach its suppliers' labels to a finished product. OSHA said the fabricator had to assess the final product's hazards and make one label identifying itself and…
Anti-two-blocking devices for cranes lifting personnel
A construction company sought delay or relief from a crane anti-two-blocking rule. OSHA said an earlier compliance delay had expired and that lifting personnel by crane was generally barred unless…
Strobe light versus audible backup alarm on loaders
An asphalt company asked whether it could use a strobe light instead of an audible reverse alarm on a loader. OSHA said the light did not satisfy the construction standard. It discussed the rule's…
Disinfectants for blood cleanup and dental protective clothing
A regional office asked about disinfectants for blood cleanup and sleeve coverage for dentists. OSHA said an HIV-only product could be used where HIV was the only pathogen of concern; if hepatitis B…
HAZWOPER training for occasional repair workers at disposal sites
An equipment service company asked if mechanics visiting a disposal site for repairs needed HAZWOPER training. OSHA said workers exclusively in uncontaminated areas, outside hazardous areas, and…
Target organ warnings on in-plant chemical labels
A manufacturer asked whether coded workplace labels had to show target organ effects and whether chemicals used across shifts counted as immediate-use containers. OSHA said coded labels could be…
Government recognition of voluntary hazardous waste cleanup sites
A regional office asked when a voluntarily cleaned hazardous waste site was recognized by a government body for HAZWOPER coverage. OSHA said written acknowledgment, or willingness to acknowledge in…
Inspecting braided wire rope slings without removing seizing
A requester asked whether inspection of braided wire rope slings required removing the protective wire or plastic wrapping around a loop. OSHA said daily inspection needed more than a glance where…
Use of merged DD-214 forms for ex-servicemember unemployment claims
ETA told state unemployment agencies how to handle merged copies of military discharge Form DD-214 submitted with ex-servicemember claims. A state may use a merged copy after the Louisiana Claims…
Needle sheath for recapping and sharps disposal
A device maker asked whether a needle sheath could protect workers during recapping and serve as a disposal container. OSHA said the proposed finger guard was too small for safe two-handed…
Electronic access to material safety data sheets
An information system provider asked whether its electronic hazard database could replace material safety data sheets. OSHA said computers or fax could deliver sheets if workers could obtain…
IRA investment in a condominium and mortgage guarantee
EBSA addresses two self-directed IRAs’ proposed purchase of a condominium through a corporation. It said purchase from a developer represented not to be a disqualified person would not be a…
Fire brigades and portable extinguisher duties
An attorney asked when workplace fire brigade and extinguisher rules applied. OSHA said organized employee groups fighting even incipient fires were fire brigades subject to the relevant rule, with…
Hazard warnings on carbon and graphite products
An industry group sent draft warning label guidance for carbon and graphite electrical products. OSHA said it did not approve the guidelines, but explained that suppliers must label…
Jacobs Engineering employee stock purchase plan status
An employer asked whether its employee stock purchase plan was an ERISA benefit plan. EBSA said its stated terms provided neither welfare benefits nor retirement income or deferred pay, so it was…
Self-sheathing syringes and one-handed needle recapping
A syringe maker asked OSHA to review two needle safety systems. OSHA said it did not approve medical devices, but the described self-sheathing needle and one-handed recapping method were permitted…
OSHA enforcement at Energy Department contractor facilities
A congressman asked OSHA to investigate safety issues at Energy Department nuclear facilities. OSHA said government-owned, contractor-operated facilities were then exempt from its enforcement under…
Cytotoxic drug mixing in a pharmacy and the laboratory standard
A safety consultant asked whether pharmacy staff mixing cytotoxic drugs worked in a laboratory under OSHA's laboratory standard. OSHA said the described operation resembled a production process with…
Formaldehyde protection in gross anatomy laboratories
A medical college association asked how anatomy teaching labs should apply OSHA's formaldehyde rule without obstructing instruction. OSHA said protective equipment depended on each task and…
Forklift brake drawbar drag under later ANSI revisions
A forklift maker asked about a later consensus standard reducing brake drawbar drag from 30% to 25%. OSHA said its rule incorporated an older ANSI edition, but it would accept a newer, less…
Patient nurse call system outside OSHA worker safety jurisdiction
A communications installer asked OSHA about a hospital call system that might prevent a patient from signaling a new emergency. OSHA said the described problem concerned patient safety rather than…
Derby Association health trust as a MEWA
The request asked whether the Derby Association Trust was a MEWA. EBSA found that it served workers of separate employers, making it a MEWA open to state insurance regulation under ERISA. It did not…
Group Rental Insurance Plan medical trust as a MEWA
The request asked whether a rental-industry medical trust was a MEWA. EBSA found that it provided benefits to employees of separate employers and was a MEWA, so ERISA allowed state insurance…
Self-directed IRAs buying stock of custodian affiliate
An IRA custodian asked about participants buying stock of its parent company through self-directed IRAs. EBSA said purchases from the custodian itself would be prohibited sales under the cited rule;…
Alarm Association of Florida health plan as a MEWA
The request asked whether an alarm industry health plan avoided state insurance law through ERISA. EBSA concluded that it served employees of separate employers and was a MEWA, so state regulation…
Consumer products and hazard communication in veterinary clinics
A congressman asked whether a veterinary clinic needed safety sheets for common household products, including vinegar and starch. OSHA said products used with consumer-like frequency and duration…
Hazard communication duties for products imported into the United States
An overseas manufacturer asked when its products needed material safety data sheets for U.S. distribution. OSHA said the maker or importer had to assess foreseeable workplace exposure and provide…
Dry drilling jurisdiction between MSHA and OSHA
A congressman asked about hazards from dry drilling. OSHA said drilling directly related to mining ordinarily fell under the Mine Safety and Health Administration, while oil, gas, and water well…
Ventilation and alarms in ammonia refrigeration control rooms
A regional office asked about explosion and inhalation hazards in an ammonia refrigeration control room. OSHA said the unventilated room warranted a citation, while installing ventilation meeting…
Rescue skiffs for construction work over water
A construction industry group asked when a lifesaving skiff is immediately available for work over water. OSHA said the skiff should be able to retrieve a worker within three to four minutes at…
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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.