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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Commuting from a Colombian oilfield to a worker accommodation camp
A Colombian oilfield operator asked whether an incident on workers’ trip from the field to their accommodation camp was work-related. OSHA said the camp could be a home away from home, making that…
Exit-route stair widths and renumbered medical-record standards
A safety consultant asked how 22-inch industrial stair rules interact with a 28-inch exit-access minimum and why medical-record citations still used an older section number. OSHA said exit-route…
Leather work gloves as protective equipment for utility workers
A utility union asked whether leather gloves and rubber-glove protectors counted as protective equipment and who paid for them. OSHA said both types of leather glove were protective equipment, and…
Recording a traffic injury during travel from off-site training
A requester asked whether injuries from a crash while leaving off-site training should be logged. The worker was traveling to the office for a customer-related errand, and OSHA said the trip served…
Medical certification under a sick-leave policy
WHD considered whether an employer’s sick-leave medical certification policy was less stringent than FMLA requirements when paid leave was substituted. It concluded the described policy was more…
Interim PSM enforcement at oil and gas production facilities
OSHA told regional administrators it would not enforce the process safety management standard at oil and gas production facilities while it studied feasibility. The memo expressly withdrew its…
Documenting a gas-oven lockout procedure during maintenance
A consultant asked whether a company could omit a written energy-control procedure for oven maintenance under an eight-condition exception. OSHA said natural gas created a thermal energy hazard and…
Longshoring rules for cargo handling aboard docked vessels
A lawyer asked whether marine-terminal or longshoring rules governed cargo movement aboard vessels or barges docked at a terminal. OSHA said Part 1918 governs cargo handling aboard the vessel, but…
Site-specific training for powered industrial truck operators
A forklift maker asked whether a general course and obstacle-course exercise qualified attendees as operators at different workplaces. OSHA said trainers need appropriate knowledge and experience,…
Minimum disaster unemployment benefit amounts for spring 2000
ETA supplied state agencies with minimum weekly Disaster Unemployment Assistance amounts for major disasters declared from April 1 through June 30, 2000. Its attachment lists each jurisdiction's…
Vocational rehabilitation representation on State Workforce Investment Boards
ETA sent states a joint Labor and Education interpretation of how vocational rehabilitation (VR) programs should participate in State Workforce Investment Boards under the Workforce Investment Act.…
Three union employees in Tulsa firefighters health plan
A Tulsa firefighters welfare trust asked whether coverage of one union employee and two prospective union employees would change its ERISA status. EBSA said the plan remained governmental despite…
Commercial diver qualifications and training credentials
A senator asked on behalf of a constituent which diving schools, consensus-standard training, or licenses could demonstrate dive-team qualifications. OSHA described training documentation and…
Santa Barbara housing authority pension as governmental
A California housing authority asked whether its employee pension plan was excluded from ERISA Title I. EBSA found the authority was a governmental agency or instrumentality because state law…
Safety instrumented systems under process safety management
A standards organization asked whether following ANSI/ISA S84.01 ensured compliance with process safety management rules for safety instrumented systems. OSHA said the standard is a recognized…
Funds for exemplary youth activities peer-to-peer learning projects
ETA invited local workforce boards to apply for grants to host peer learning forums about their youth programs during the transition to the Workforce Investment Act. It expected 10 to 12 awards of…
Lockout versus tagout for overhead HVAC maintenance
A consultant asked whether a nearby overhead disconnect under a technician’s control exempted heat-pump maintenance from lockout rules. OSHA said the cord-and-plug exception did not apply, and…
Safety incentive programs and injury underreporting
An oil-and-gas safety superintendent described a program using job-safety analyses and incentives. OSHA said it did not approve or disapprove a particular incentive design or effectiveness, but did…
Process safety coverage of an LPG bottle-filling facility
A consultant asked whether an LPG bottle filling plant with more than 10,000 pounds in bulk storage was covered by process safety management rules. OSHA said interconnected storage and filling…
Tunnel lighting during ventilation-system removal
An OSHA regional office asked whether workers traveling through a long tunnel and removing diffuser plugs needed the underground-work lighting level. OSHA explained how the work-in-progress rule…
Disposal containers for used plastic blood collection tubes
A medical-products company asked whether used plastic blood collection tubes could go into red bags or needed puncture-resistant containers. OSHA said they are regulated waste and that the container…
Hepatitis B booster and antibody testing under the bloodborne pathogens rule
A federal aviation medical officer asked if OSHA required a hepatitis B booster after vaccination. OSHA said the cited public-health guidance did not then recommend a booster, but did call for…
Electric utility safety training for managers called to field work
An Alaska safety official asked whether upper managers needed annual craft training when they normally did not work on power lines but might help after a disaster. OSHA said training duties depend…
Release procedures for 1999 unemployment benefit accuracy data
ETA set procedures and deadlines for reviewing and releasing states' calendar 1999 Benefit Accuracy Measurement results. States could choose whether to publish their own data, but had to reconcile…
Skid steers with forks under powered industrial truck rules
A landscape association asked if earthmoving vehicles with removable forks count as powered industrial trucks. OSHA said an earthmoving skid steer remains outside that rule when designed and used as…
Unemployment Trust Fund payment and deposit system transition
ETA told state unemployment agencies about a transition to Treasury's ASAP payment system and CASHLINK deposit processing for Unemployment Trust Fund transactions. States were asked to have their…
Driver hours and off-duty injuries under former trucker recordkeeping guidance
A trucking association asked how to count driver hours and whether injuries while sleeping, bathing, or eating on the road were work-related. OSHA said work tasks and necessary travel counted as…
Recording injuries of contract workers under day-to-day supervision
A manufacturer asked who recorded injuries of contract workers assigned to its site. OSHA said the key under its former Log 200 guidance was which firm controlled the workers’ day-to-day methods,…
Recording minor wounds when workers are kept out of radiological areas
A construction employer asked if minor scratches became recordable when workers were temporarily kept out of radiological areas to avoid contamination. OSHA said the described cases were not…
Negotiating WIA performance goals and incentive and sanction process
ETA set a process for states and its regional offices to negotiate WIA performance levels and explained how performance would be considered for incentive grants and sanctions. The attachments supply…
Safety bonuses tied to reported accident counts
A worker asked whether a bonus could be cut when managers thought too many accidents were reported. OSHA said its then-current rules did not prohibit that bonus arrangement, but employers had to…
Pennsylvania Catholic college benefit plans as church plans
A Pennsylvania Catholic college asked whether its benefit plans were church plans. EBSA agreed with the IRS’s private ruling if the college and plans still operated as described to the IRS and no…
Roof jacks and a former residential fall-protection directive
A contractor asked when roof jacks or slide guards could protect residential roofers and whether they applied on a commercial roof. OSHA explained a fall-protection-plan exception and then discussed…
Work-Flex transition guidelines under WIA
ETA explained how states could seek Work-Flex authority under the Workforce Investment Act and how the six demonstration states could transition from JTPA. Governors could approve certain local…
Union employees joining an Alaska governmental welfare trust
An Alaska public employees trust asked whether covering 11 union staff who represent public workers would end its governmental-plan status. Assuming the existing trust qualified, EBSA said this…
Backdated interstate claims and elimination of Form IB-3
ETA told states to post each week claimed on a backdated interstate initial claim in the Interstate Connection withdrawal or invalid claim application. Until every state could use that application,…
Military separation reasons for ex-servicemember unemployment claims
ETA added early separation under the Army National Guard Combat Reform Initiative to the reasons that can qualify former service members for unemployment benefits. Because a discharge form alone did…
WIA program year 2000 allotments and Wagner-Peyser preliminary estimates
ETA announced state and outlying area allotments for WIA youth, adult, and dislocated worker activities for program year 2000 and preliminary Wagner-Peyser employment service estimates. It explained…
PY 2000 Wagner-Peyser agriculture services planning guidelines
ETA told state workforce agencies how to prepare their PY 2000 Agriculture Services Submissions under the Wagner-Peyser Act. The required plan covered farmworker needs, outreach, service levels,…
New hearing baseline when a worker returns to an employer
A state labor official asked whether a company could use an employee’s old hearing test after the employee spent six months working elsewhere. OSHA said the company should establish a new baseline…
Mechanical removal of asbestos-containing floor mastic
A Utah OSHA lawyer asked whether a wet floor and rotating blade could be used to remove asbestos-containing mastic. OSHA said the aggressive method requires an employer evaluation showing less…
Retention of powered industrial truck inspection records
A plant engineer asked how long forklift examination records must be kept. OSHA said the rule requires examination before service and correction of unsafe defects, but does not require written…
Recording a head injury caused by an epileptic seizure at work
A refinery asked whether a head laceration needing stitches after an employee had a seizure at a desk belonged on its injury log. OSHA said the resulting injury was presumed work-related because the…
Recording break-time walking injuries and infrequent restricted tasks
A consultant asked if injuries during exercise walks on ordinary company grounds were work-related and whether a temporary climbing restriction counted when climbing was scheduled only four times…
Federal military remuneration schedule for UCX claims in 2000
ETA gave state unemployment agencies a revised military pay schedule for calculating federal wages in ex-servicemember unemployment claims. States were to use it for qualifying first claims filed…
Minimum disaster unemployment benefit amounts for early 2000
ETA supplied state agencies with a table of minimum weekly Disaster Unemployment Assistance amounts for major disasters declared from January 1 through March 31, 2000. The table lists each…
Comprehensive youth services under WIA in summer 2000
ETA guided state and local workforce programs through the first summer under the Workforce Investment Act. Summer jobs became one element of a year-round youth development strategy, with assessment,…
Importer name and responsibility on chemical safety data sheets
A lawyer asked whether an importer could list its own name instead of a Japanese manufacturer on a material safety data sheet. OSHA said a downstream firm that substitutes its name takes…
Computer display radiation and OSHA standards
An office worker asked about potential health effects from low-frequency emissions from computer displays. OSHA said it had no standard addressing those emissions and that its ionizing-radiation…
Tag attachment strength when a utility device cannot accept a large tie
A utility asked whether a tag attachment could fall below the 50-pound unlocking-strength rule when the device cannot accept a standard cable tie. OSHA said it would treat a weaker tie as de minimis…
Fall protection while working from construction ladders
A mechanical contractor asked whether OSHA requires personal fall protection on ladders above six feet. OSHA explained specific fixed-ladder requirements for climbs or tops above 24 feet, while…
Withdrawal of an earlier home-worksite interpretation
OSHA notified a requester that it was withdrawing its November 15, 1999 letter about employees working at home. It said the earlier guidance caused widespread confusion and unintended consequences.…
Removal terms for trustees of a funded welfare plan
A union asked whether welfare-plan trustees could remain indefinitely unless removed for cause under their reading of a trust agreement. EBSA said service arrangements must allow reasonably prompt…
Grounding and GFCI alternatives in a nursing home
An OSHA regional office asked whether a nursing home could install ground-fault circuit interrupters instead of grounding receptacles serving appliances. OSHA said a GFCI does not replace the…
Withdrawn PSM interpretation for oil and gas production facilities
OSHA told regional administrators that oil and gas production processes containing at least 10,000 pounds of flammable material fell under its process safety management rule. Its April 11, 2000…
Reinstated unemployment data disclosure to housing agencies
ETA told state unemployment agencies that a federal requirement to disclose wage and benefit information to HUD and public housing agencies had been reinstated for requests made after October 27,…
Conflicting medical opinions on restricted duty at a Canadian site
A Canadian employer asked how to classify days when one doctor recommended restricted duty and another recommended absence after a contractor’s injury. OSHA said the employer could reasonably weigh…
Three injury-recording cases for a Virginia county
A Virginia county asked how to record three employee cases. OSHA said a firefighter’s cancer death and carbon monoxide poisoning were recordable under the former log, while a brief hearing shift…
Medical treatment choices and injury-recording incentives
A physician asked whether a prior OSHA recordkeeping letter endorsed giving nonprescription drugs above recommended doses to avoid a recordable case. OSHA said it did not endorse treatment outside…
Injuries during voluntary physical exams on employer premises
An employer asked OSHA to exempt injuries arising solely from voluntary medical exams held on its premises. OSHA said its then-current rules presumed those cases work-related when recording criteria…
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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.