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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Hazard labels on vehicles and workplace machines
A paper company asked whether lift trucks and machines containing hazardous chemicals need container labels. OSHA said vehicles and machine components are generally not containers under the Hazard…
Safety monitors on low-pitch roofing work
An OSHA regional office asked when a safety monitor could replace a physical fall protection system. OSHA said the then-current exception was limited to built-up roofing on low-pitch roof…
Special trucks for moving compressed-gas cylinders
A safety-cap maker asked what OSHA means by a special truck for moving compressed-gas cylinders and whether its cap could replace one. OSHA said a special truck is a cart or vehicle that stably…
Appeal rights for ETA federal-assistance grantees
ETA told federal-assistance grantees how to appeal a final audit determination when no statute or regulation established another appeal process. For those grants, ETA selected a hearing before the…
Alarm devices versus automatic anti-two-blocking protection
A contractors' association asked whether alarms could satisfy the crane personnel platform anti-two-blocking requirement. OSHA said alarms depended too heavily on operator reaction time and did not…
Annual bakery-oven inspections by a qualified burner company
A burner company asked whether its personnel could conduct required annual inspections of bakery ovens at customer sites. OSHA said qualified representatives of an oven manufacturer who know the…
Child care assistance for unemployment claimants
ETA encouraged state unemployment offices to help claimants with child care responsibilities by providing relevant information and assistance. Current status is unconfirmed.
State waivers for SAVE unemployment eligibility verification
ETA decided which state unemployment agencies could avoid the automated part of the SAVE immigration-status verification program in 1988. Six states received waivers and three did not; every state…
Revised alien wage-credit interpretation
ETA revised its interpretation of when certain lawfully admitted temporary residents’ prior wages may count toward unemployment monetary eligibility. ETA still lists the letter as continuing.
Transfer of assets in a welfare-plan merger
A plan administrator proposed merging an employer's disability and medical plans and moving related assets and liabilities into the merged plan. EBSA said that transfer alone would not violate the…
Crystalline silica carcinogenicity warnings under hazard communication
A stone-industry group asked OSHA to say crystalline silica should not be treated as a carcinogen for hazard communication. OSHA denied the request, citing scientific evidence and the standard’s…
Taut rope and chain guardrails on shipyard scaffolds
A shipbuilding association challenged OSHA's meaning of taut for rope or chain scaffold guardrails. OSHA disagreed and said guardrails meeting the criteria in its cited directive were taut under the…
Trustee compensation from pension and welfare plans
A requester writing for two plans asked whether a trustee could receive compensation from them while receiving full-time pay from a construction company. EBSA said the company’s ties did not bar…
Public school money-purchase plan as governmental
A school system asked whether its money-purchase retirement plan was covered by ERISA Title I. EBSA said the plan was established and maintained by a Virginia public school agency for its employees…
Bank trustee investment in premium-fee common funds
A bank asked whether plan assets could enter common trust funds with premium fees under an arrangement approved by independent plan decision-makers. EBSA said investment under the stated safeguards…
Hazard communication exemption for waste samples sent to a lab
A safety consultant asked whether hazardous-waste samples sent to a lab for analysis lose their Hazard Communication Standard exemption. OSHA said samples sent as part of disposal preparation remain…
Dependent-care reimbursements and ERISA welfare-plan status
An employer paid or reimbursed workers for child care of their choice without sponsoring a specific center. EBSA said the program did not provide the type of benefit listed in ERISA section 3(1) and…
Deadline to replace open-tip standpipe hose nozzles
A fire-protection company asked when open-tip nozzles on standpipe hose had to be replaced with shut-off nozzles. OSHA clarified that the deadline was by July 1, 1981, rather than sometime after…
Proof testing of synthetic web slings
An OSHA regional office asked whether a contractor could repeatedly proof test synthetic web slings above their rated load. OSHA said proof testing and certification generally belong to the…
Interim enforcement of hazard communication outside construction
OSHA told regional administrators how a court stay affected enforcement of the expanded Hazard Communication Standard in 1988. It said the stay applied to construction employers, while other…
Employee access to safety data sheets and written hazard programs
An employer asked whether it must provide employees’ representatives with safety data sheets and the written hazard communication program. OSHA said the first request for an exposure record must be…
Qualifications for hazardous waste safety trainers
A health services manager asked what qualifications instructors needed for interim HAZWOPER training. OSHA said the rule set no fixed degree or credential; instructors needed training at a higher…
Training for low-exposure hazardous waste site workers
A waste site services firm asked whether employees who did not disturb hazardous materials needed HAZWOPER training. OSHA said workers neither exposed nor potentially exposed did not need the cited…
Avoiding unsupported target-organ warnings on labels
An OSHA regional office asked whether a manufacturer could use the same broad list of target-organ hazards on every product in a line. OSHA said each listed hazard must be demonstrated by at least…
Direct-reading instruments and objective data at waste sites
A cleanup firm asked whether direct-reading instruments and objective data could satisfy interim HAZWOPER monitoring rules. OSHA accepted direct-reading tools for initial characterization if they…
Confidentiality and retention of occupational medical records
A lawyer asked how an employer can retain required employee medical records without learning unrelated medical details. OSHA said non-healthcare managers receive only occupationally relevant…
Carcinogen labels for IARC category 2B chemicals
A company asked whether chemicals classified by IARC as category 2B always need a cancer warning on their labels. OSHA said all relevant hazards belong on the material safety data sheet, but label…
Fall protection on ladder jack scaffolds
An OSHA regional office asked whether a general scaffold guardrail rule applied to ladder jack scaffolds. OSHA said it did not and that the then-current ladder jack provisions had no fall protection…
Omitting inapplicable sections from material safety data sheets
State plan officials asked whether a material safety data sheet must display every possible information field, even when a field is inapplicable. OSHA said a preparer may omit an entire inapplicable…
UCFE claims from decennial census employment
ETA assigned a separate federal identification code for Census Bureau claims and asked state agencies to coordinate processing of the expected wave of claims from temporary census workers. Current…
Temporary oil-heater safeguards at construction sites
An OSHA regional office asked whether a temporary oil heater met construction standards. OSHA said the model’s integral fuel tank made a separate flame-loss shutoff unnecessary, while users still…
Hazard communication training for short chemical-exposure tasks
A lawyer asked whether brief chemical-exposure tasks require hazard communication training and whether a short oral presentation can suffice. OSHA said coverage depends on possible exposure during…
Inapplicable fields on material safety data sheets
OSHA clarified whether an earlier interpretation allowing omitted inapplicable safety data sheet sections applied only to computer-generated sheets. It said the rule sets no fixed format, so…
Floral shop products under hazard communication rules
A florist asked whether it needed material safety data sheets for supplies. OSHA treated manufactured floral foam as an exempt article, discussed a then-current consumer product exclusion, and said…
Medical examinations after chromic acid exposure
An OSHA medical officer clarified examination timing under the chromic acid rule. The memorandum said periodic exams meant yearly unless stated otherwise, and a physician should evaluate skin after…
Pension offset requirements under FUTA
ETA consolidated its interpretations of FUTA pension offset requirements for state unemployment compensation. The official issue-date header and 2025 checklist both give April 30, 1988. ETA still…
Consumer use exemption for liquid plant food under hazard communication
A plant-food supplier asked whether it had to supply material safety data sheets. OSHA said the Hazard Communication Standard does not apply to consumers. For workplace customers, the…
Directed IRA purchases of a bank parent company stock
A bank asked whether self-directed IRAs could buy its parent company stock. EBSA said the specified sale prohibition did not apply where the seller was not a disqualified person, but warned that…
Sheep-ranching exception to temporary labor camp livestock setback
An agricultural employers association asked how the 500-foot livestock setback for temporary labor camps applies to sheep ranches. OSHA said short-term housing of sheep for medication, shearing,…
Rated capacities for alloy steel chain slings under revised ASTM A391
A sling supplier asked about rated capacities after ASTM revised its alloy steel chain standard. OSHA said the table in 29 CFR 1910.184(e) applies to A391-65 material; slings made from the new…
Monthly release of leveraged ESOP securities
A requester asked whether a bank's ESOP could release pledged employer securities monthly or annually. EBSA said monthly releases were permissible if the total released in a plan year met the…
Equivalent courses for asbestos competent-person training
OSHA told regional offices what training counted as an equivalent course for the competent person supervising asbestos enclosure work. It identified EPA-accredited or approved state…
Wire rope and steel banding as construction guardrails
An OSHA regional office asked whether wire rope and steel banding rails gave protection equivalent to standard construction guardrails. OSHA said the performance rule did not fix post spacing, so…
Golf association retirement arrangement and ERISA plan status
EBSA said a golf association’s retirement arrangement was not itself an ERISA pension plan because the association was neither a qualifying employer group nor an employee organization. An employer…
Employee association supplemental sick-benefit fund
EBSA said an employee association’s supplemental sick-benefit fund was an ERISA welfare plan. It also discussed which entity was the plan administrator and when the employer could be a functional…
Church and school association benefits plan as a MEWA
EBSA said a church and school association’s benefits plan was a multiple employer welfare arrangement subject to applicable state insurance law, even if its separate ERISA welfare-plan status…
Multiple-load crane hoisting during steel erection
An OSHA regional office told field staff how it would assess cranes lifting several steel loads at once during erection. It said the practice could support a general duty citation if the recognized…
Waiver criteria for immigration status verification
ETA explained when the Secretary would waive a state from automated immigration-status verification, identified criteria for waivers, and described minimum verification duties that would remain. ETA…
ERISA status of an employee assistance program
EBSA said the described employee assistance program was an ERISA welfare plan insofar as it provided benefits listed in ERISA section 3(1). The opinion concerned only that program and did not decide…
Formaldehyde protection using approved chin-style respirator canisters
A respirator manufacturer submitted test data for chin-style formaldehyde canisters omitted from OSHA's respirator selection table. After reviewing the data with NIOSH, OSHA accepted the approved…
Criteria for changes to the UI quality-control questionnaire
ETA set criteria for reviewing state changes to the unemployment quality-control claimant questionnaire, including state-law fit and preservation of uniform data collection. Current status is unconfirmed.
Unemployment insurance quality-control questions and answers, Change 2
ETA answered state agencies' questions about how to investigate unemployment benefit payments for quality control. It addressed interstate information delays, claimant interviews and mailed…
Grounding a construction transformer secondary circuit
An OSHA regional office asked whether a described construction transformer secondary system had to be grounded. OSHA said the 120/240-volt configuration met the cited grounding condition and the…
English labels and optional additional languages under hazard communication
A safety consultant asked whether employers must provide Hazard Communication Standard materials in a language other than English. OSHA quoted the label provision requiring legible English warnings…
Plan reimbursement of direct investment-service expenses
EBSA said reimbursement of direct investment-service expenses did not itself violate the cited fiduciary self-dealing rule. It left operational conflicts, factual expense classification, and…
1987 budget reconciliation changes to unemployment compensation
ETA summarized provisions of the 1987 Budget Reconciliation Act affecting extended benefits, self-employment demonstrations, unemployment accounts, and federal unemployment tax. Current status is…
Hexavalent chromium in photocopier toner safety sheets
A consultant asked whether toner containing 0.003 percent hexavalent chromium needed a carcinogenic warning on a material safety data sheet. OSHA said the evidence supplied did not establish…
Physician review and removal protection under the lead standard
A company asked how the lead standard's physician review process and medical removal benefits apply to an employee. OSHA said the multiple-physician process starts after an examination by the…
Quality-control case-file monitoring guidelines
ETA gave state agencies detailed guidance on how federal regional staff would assess unemployment quality-control case investigations and record exceptions. Current status is unconfirmed.
Bank cash-sweep services for employee benefit plans
EBSA said a bank’s cash-sweep service could qualify for the ERISA service exemption if its conditions were met, and the described fees did not themselves violate the specified self-dealing rules. It…
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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.