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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Protective clothing for bloodborne pathogen exposure
A protective-equipment maker asked what quality criteria OSHA applied to clothing used against bloodborne pathogens. OSHA said it had no specific biological-resistance specification and that…
Requirements for federal approval of a state OSHA plan
A state employee asked how a state could obtain federal approval for its own occupational safety and health program. OSHA explained the application, state legal authority, standards, enforcement,…
Keys for locked exits and the meaning of occupied
An OSHA regional office asked how the exit rule applied to doors requiring a key from the egress side. OSHA said later NFPA definitions that treated a building as occupied only above a ten-person…
Recording occupational hearing loss on OSHA Form 200
A marine company asked when hearing loss had to be recorded on the former OSHA Form 200 log. OSHA described the then-used 25-decibel cumulative shift threshold, how a recordable audiogram became the…
Mandatory implementation of Revenue Quality Control
ETA laid out when state unemployment agencies would begin mandatory Revenue Quality Control reporting and review of tax operations. Computed measures and revised Form ETA 581 reporting were…
Glutaraldehyde hazard information for health care workers
A member of Congress asked how workers using glutaraldehyde in health care would learn about newly identified hazards. OSHA said chemical makers and importers had to update safety data sheets after…
Notice of Extended Benefits status changes from unemployment rate trigger
ETA said it would notify a state official when the alternative three-month total unemployment rate changed the state's Extended Benefits status and explain the circumstances. States still had to…
Emergency eyewash and showers in extreme temperatures
An equipment company asked how emergency eyewash and showers should work outdoors in freezing or hot conditions. OSHA said employers must provide reliable equipment that flushes corrosive material…
Bloodborne pathogen rules for human cell lines and strains
A biological safety association asked OSHA to clarify coverage of established human cell lines. OSHA said well-characterized lines shown free of bloodborne pathogens could fall outside the standard,…
Kentucky literacy center in county retirement system
Representatives of a county-created literacy center asked whether its participation in the county retirement system would affect the system's governmental-plan status. EBSA said the center was a…
Association health and life program as a MEWA
A requester asked whether the described association health and life insurance program was a multiple employer welfare arrangement. EBSA said it was, because participation spanned more than one…
Flammable aerosol adhesives and spray-finishing rules
A manufacturer asked whether flammable aerosol adhesives used to bond wood panels fell under OSHA’s spray-finishing standard. OSHA said the described cans and cylinders were generally covered,…
Cadmium urine sampling and biological monitoring
A company asked how to obtain accurate urine samples for cadmium biological monitoring. OSHA said prehydration could make samples too dilute and recommended an initial sample without drinking water…
Religious Freedom Restoration Act and unemployment claims
In 1994, ETA told state unemployment agencies to apply the federal Religious Freedom Restoration Act when a state rule burdened a claimant's religious practice. The letter reviewed earlier Supreme…
Appalachian Regional Commission pension as governmental plan
The Appalachian Regional Commission asked whether its pension plan qualified for ERISA’s governmental exemption. EBSA said the commission was a federal and state instrumentality created, controlled,…
Interim fall protection policy for roofing work
OSHA told field offices how to cite fall-protection violations in steep-roof and built-up roofing work while a new construction rule was pending. The memorandum limited citations to failures under…
Cleaning blood-contaminated carpet under OSHA rules
A supplier asked how employers should handle blood or other potentially infectious material spilled on carpet. OSHA withdrew its earlier suggestion that plush carpet could be decontaminated, saying…
Process safety coverage of hazardous chemical mixtures
An environmental services company asked when gases and mixtures of listed hazardous chemicals fell under OSHA’s process safety management rule. OSHA explained how Appendix A listings,…
Confined-space settlement and gas industry coverage
OSHA circulated a settlement concerning its confined-space standard and gas-industry operations. The memo said Department of Transportation pipeline rules governed many such operations, including…
Davit-arm hoisting of workers in a boatswain chair
A company asked whether a dedicated davit-arm system could lift workers in a boatswain chair during submarine ballast-can work. OSHA said the described system appeared safe and feasible and would…
Process safety threshold quantity for ammonia systems
A safety consultant asked whether a large ammonia system triggered process safety rules when it was filled below the threshold quantity. OSHA said coverage depended on the amount actually present at…
Historical reporting of multiple hospitalizations
A lawyer asked how OSHA’s then-current fatality and multiple-hospitalization reporting rule counted workers from different employers. OSHA confirmed that the duty applied to an employer’s own…
Recording back injuries and carpal tunnel on Form 200
A risk manager asked when back injuries and carpal tunnel cases belonged on the former OSHA Form 200. OSHA said workers’ compensation decisions did not control the log; work-related carpal tunnel…
Chimney platform gaps and falling-object protection
An engineering firm asked whether a narrow gap between a chimney and surrounding work platform was allowed and when toeboards were needed. OSHA said the proposed two-inch gap was within the…
Respirator exhalation valve leakage and tuberculosis
Health care employers asked whether valved respirators exposed workers to tuberculosis through inward leakage. OSHA said properly maintained exhalation valves leaked very little and a valveless…
Princeton Theological Seminary employee plans as church plans
A Presbyterian seminary asked whether its employee benefit arrangements were church plans. EBSA said the church’s control of the seminary and its associated plan committee met the church plan…
Tag lines for structural steel lifting
A crane training institute asked whether tag lines were required every time a structural steel load moved. OSHA said the then-applicable rule required control of hazardous loads, so tag lines were…
Needlestick injuries on the former OSHA Form 200
A health care organization asked when needlestick injuries belonged on the former OSHA Form 200. OSHA listed the then-used triggers, including work restriction, medical treatment beyond first aid,…
Recording heat-related disorders on OSHA Form 200
A law firm asked when heat-related illness had to be recorded on the former OSHA Form 200. OSHA said diagnosed or recognized work-related heat rash, cramps, exhaustion or stroke were recordable, and…
Foot protection against falling objects at construction sites
A senator asked whether OSHA required steel-toed shoes for all workers exposed to falling objects. OSHA said the cited fall-protection rule did not impose a blanket steel-toed-shoe requirement;…
Postal worker sick leave for newborn care
WHD considered a Postal Service employee who wanted to use accrued sick leave while taking FMLA leave to care for a newborn. It said the FMLA's paid-leave substitution rule did not require that use…
Aqueous hydrofluoric acid and process safety coverage
A company asked whether aqueous hydrofluoric acid fell under OSHA’s process safety management listing for anhydrous hydrogen fluoride. OSHA said aqueous solutions such as 49 percent hydrofluoric…
Bloodborne pathogen rule and construction workers
A construction safety director asked how OSHA’s bloodborne pathogens rule applied at construction sites. OSHA said construction work itself was outside that rule, but covered maintenance staff or…
Dual JTPA and senior employment program eligibility
ETA answered eight questions about joint projects under the Job Training Partnership Act and the Senior Community Service Employment Program. It said written agreements can allow eligible senior…
Completing the former OSHA Form 101
A manufacturer asked which fields of the former OSHA Form 101 had to be completed and what to do when facts were missing. OSHA said all questions had to be addressed within six workdays, unknown…
Voluntary overtime as lost workdays on Form 200
A company asked whether missed voluntary weekend overtime counted as lost workdays after a work-related injury or illness. OSHA said it counted if the worker was scheduled or had a clear pattern of…
Lifting two loaded freight containers together
A longshore union asked whether two loaded freight containers could be hoisted together using locking cones. OSHA said the practice was unsafe because shifting cargo made loads on the connectors…
Disinfectants for blood spills on hard surfaces and carpet
A cleaning company asked which products it could use after blood or other potentially infectious material spills. OSHA described its then-current disinfectant policy for hard surfaces, while saying…
Recordkeeping exemption for motor vehicle dealerships
OSHA told regional recordkeeping staff that some motor vehicle dealerships had been cited for lacking the former injury and illness logs. The memo said SIC 55 was normally exempt under the…
Annual written tests in place of refresher training
A company asked whether a properly designed test could replace repeated annual safety training. OSHA said an annual written test might suffice where hazards and duties remained the same, but a test…
COBRA initial notice to an uncovered spouse
An individual asked whether group health plans must send a COBRA initial notice to an employee’s spouse even when the spouse was not covered. EBSA said the notice duty for a spouse arises only when…
Needle recapping device under bloodborne pathogen rules
An inventor asked OSHA to assess a device meant to cover used needles before disposal. OSHA said it did not endorse products, but the described device appeared to be a recapping tool rather than a…
Impermeable bags for asbestos waste disposal
A bag manufacturer asked what specifications and tests OSHA required for asbestos waste bags. OSHA said its standards set performance requirements rather than prescriptive bag tests: the bag must be…
Asbestos monitoring and PPE during emergency response
A utility asked whether real-time instruments could justify reducing protective equipment during an asbestos release. OSHA said the asbestos and emergency-response rules both applied, with the more…
Source-patient blood testing after workplace exposure
A hospital asked whether it needed a separate physician order before testing a source patient’s blood after an employee exposure. OSHA said a hospital policy could provide for testing without that…
Cadmium content and labeling of installed products
A manufacturer asked when installed products containing trace cadmium needed a visible indication. OSHA said labeling was required at 0.1 percent cadmium or more, and below that level when evidence…
Testing compressed breathing air and compressor alarms
A refinishing-products company asked how OSHA interpreted compressor alarms and breathing-air quality checks. OSHA said an oil-lubricated compressor alarm had to be audible, that testing frequency…
Growers association as joint employer under field sanitation rule
A farmworker group asked whether a Virginia growers association shared responsibility for field sanitation. On the facts presented, OSHA said the association was a joint employer under the federal…
Reusable and disposable tracheostomy cannulas under the bloodborne pathogen rule
A medical-device maker asked what protective measures a caregiver should take when re-cleaning a patient's inner cannula and whether disposable inner cannulas could be an engineering control. OSHA…
Oregon residential roofing fall protection policy
OSHA reviewed Oregon’s residential roofing fall-protection policy under its state-plan oversight role. It concluded that Oregon’s policy allowed work at greater heights and roof pitches without the…
Fall protection citations for bridge construction
Regional staff asked whether to cite two bridge contractors for failing to provide fall protection. OSHA's construction compliance office concurred with issuing one citation to each under the…
Disaster unemployment benefit amounts for April–June 1994
ETA directed state unemployment agencies to use the attached average weekly benefit amounts when calculating disaster unemployment assistance for disasters occurring April through June 1994. It said…
St. Anthony’s Hospital benefit plans as church plans
A Florida Catholic hospital asked whether its employee benefits were church plans. EBSA said the Franciscan order’s control of the hospital and its associated plan committees met the definition, and…
Presbyterian retirement home welfare plans as church plans
A Presbyterian retirement home operator asked whether its employee welfare arrangements were church plans. EBSA said the presbytery’s control of the homes and associated benefits committee met the…
Insulators apprenticeship and hazardous waste trusts under ERISA
A requester asked whether two apprenticeship and hazardous materials training trusts were ERISA welfare plans subject to reporting. EBSA said both provided employee training benefits funded by…
FMLA leave and reasonable accommodation
A requester asked whether an employer could require an employee to take a reasonably accommodated or light-duty job instead of FMLA leave. WHD said eligible employees could elect FMLA leave despite…
Crane-supported overhang form as a scaffold or personnel platform
A form-system maker asked which OSHA rules applied to a crane-supported access platform. OSHA said that, if the hoist was secured and the platform stayed still with workers on it, it would be…
Revised draft language on reemployment service participation
ETA corrected model state-law language for unemployment claimants referred to reemployment services after worker profiling. It said a claimant who completed the services or had justifiable cause for…
Safety net at open hatches as fall protection
A manufacturer asked whether OSHA would accept its net over open hatches. OSHA said it did not endorse products, but the described net appeared to provide effective added protection and might be an…
Disinfectant policy for bloodborne pathogen cleanup
A state labor official asked OSHA to clarify its bloodborne-pathogen disinfection directive. OSHA said it based the then-current disinfectant methods on CDC guidance and industrial hygiene…
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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.