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.

8,150 documents · Updated October 28, 2026
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Reeves Sleeve rescue stretcher use and training

A rescue stretcher representative asked if the Reeves Sleeve met OSHA requirements. OSHA's construction office said proper application and user training could satisfy relevant emergency rescue…

Opinion Letter June 24, 1993

Sulfuric acid and oleum under process safety management

An employer asked whether sulfuric acid fell under OSHA’s process safety management rule. OSHA said 93–98 percent sulfuric acid was outside the rule and described coverage for specified…

Opinion Letter June 24, 1993

Bloodborne pathogen duties for a utility employer

A gas company asked whether the bloodborne pathogens rule applied outside healthcare. OSHA said coverage depends on reasonably anticipated blood or other infectious material contact in employees’…

Opinion Letter June 24, 1993

Interim unemployment fund cash management under CMIA

ETA gave state unemployment agencies interim cash management instructions under the Cash Management Improvement Act while DOL regulations were pending. The letter replaced a one-day benefit-account…

Guidance June 23, 1993

Monthly employment definition on quarterly contribution reports

ETA recommended that states clarify how employers count monthly employment on quarterly contribution reports and in employer handbooks. Its proposed wording counts covered full-time and part-time…

Guidance June 22, 1993

Commercial-grade chemicals under process safety management

A chemical company asked whether Appendix A substances without stated concentration limits were exempt when commercial purity fell below 99 percent. OSHA said the commercial grades of listed…

Opinion Letter June 22, 1993

Off-shift emergency response training for chemical plants

A chemical plant asked whether off-shift workers could assist outside their own process area after hazardous releases. OSHA said the need for HAZWOPER training depends on the release hazard and…

Opinion Letter June 22, 1993

Disinfecting surfaces contaminated with blood

A hospital asked whether cleaning or protective coverings could replace disinfecting blood-contaminated surfaces. OSHA said covered surfaces must be decontaminated, discussed protective coverings…

Opinion Letter June 21, 1993

Recording skin conditions, heat illness, and blisters

An employer asked several questions about recording skin conditions, heat effects, blisters, and disputed work relationship. OSHA explained how workplace exposure or aggravation made cases work…

Opinion Letter June 21, 1993

Electronic log signatures and multiple recordkeeping scenarios

A lawyer asked eight questions under OSHA’s former injury-log system. OSHA accepted electronic certification with supporting documentation and addressed prescriptions, vaccine reactions, parking-lot…

Opinion Letter June 21, 1993

Computerized injury logs and travel to treatment

An employer asked whether a computerized injury log was available if it could be printed immediately, and whether a car crash en route to medical treatment was work related. OSHA accepted immediate…

Opinion Letter June 21, 1993

Work relationship during travel and voluntary activities

An employer asked whether injuries away from its premises counted as work related. OSHA said the former recordkeeping test turned on whether the worker was carrying out work duties or present…

Opinion Letter June 21, 1993

Recording disputed injury and illness claims

A requester asked how employers should handle disputed workplace injury claims on the former OSHA log. OSHA said employers make the recording decision based on substantive evidence and should record…

Opinion Letter June 21, 1993

Restricted work limited to the injury day

An employer asked how to record work restrictions that did not last beyond the injury day. OSHA said the case was entered without lost workdays under the former log and explained how…

Opinion Letter June 21, 1993

Carpal tunnel syndrome and work relationship in records

A requester asked how to classify carpal tunnel syndrome. OSHA explained that workplace exposure need only contribute to or aggravate the condition for work relationship under the former system,…

Opinion Letter June 21, 1993

Emergency eyewash and shower equipment for corrosive exposure

A safety equipment supplier asked what OSHA expected of emergency eyewash and shower facilities where workers could contact corrosive materials. OSHA described its quick-drenching requirement and…

Opinion Letter June 21, 1993

Reuse of contaminated uniforms during asbestos removal

A uniform supplier asked whether asbestos workers could leave a contaminated uniform in the equipment room during a break and put it back on when returning. OSHA said the described reuse violated…

Opinion Letter June 21, 1993

Twenty-four injury and illness recordkeeping questions

A meatpacking employer asked 24 questions about OSHA’s former injury and illness log. OSHA explained how it classified treatments and conditions, including medicines, wound closures, blisters, and…

Opinion Letter June 18, 1993

Steel-toe footwear for electrical trades

An electrical worker asked about wearing steel-toe shoes. OSHA said it generally did not consider them hazardous if the conductive part was neither exposed nor touching the foot, and pointed to…

Opinion Letter June 18, 1993

Capacity of modified portable ladders

A union asked whether adding support legs could raise the safe capacity of a portable ladder. OSHA said a modified Type 1A ladder could comply if a registered professional engineer certified the…

Opinion Letter June 18, 1993

Pulmonary function testing and respirator medical programs

A union asked whether respirator use always required pulmonary function testing and raised concerns about spirometer hygiene and tester qualifications. OSHA said testing came from certain…

Opinion Letter June 17, 1993

Training outside HAZMAT teams for waste-site emergencies

An employer asked whether an outside HAZMAT team needed full hazardous-waste-site worker training to respond anywhere on a site. OSHA said responders trained for their emergency duties under…

Opinion Letter June 17, 1993

Variance application guidance for OSHA field staff

OSHA sent field offices a handout explaining variances. It said a permanent variance is an equally protective alternative method, while a temporary variance allows time to comply with a new…

Guidance June 16, 1993

Contractor health coverage and cash benefits during FMLA leave

WHD answered a contractor asking about medical premiums during unpaid FMLA leave. It said the employer must continue group health coverage, including insurance used to satisfy a contract wage…

Opinion Letter June 15, 1993

Restricted duties for workers trained across production lines

An employer asked whether an injured worker had restricted work if a medical limit affected a job the worker was trained for but was not currently doing. OSHA said a cross-trained job was part of…

Opinion Letter June 14, 1993

Lockout and machine guarding interpretation for printing presses

OSHA told its regional offices that an earlier letter on lockout and guarding applied to printing presses only. It said references to standards for binding and finishing equipment had caused…

Opinion Letter June 14, 1993

Who supplies chemical hazard labels and data sheets

A member of Congress forwarded a concern that health workers should not have to create labels for hazardous products. OSHA said manufacturers, importers, or distributors must label outgoing…

Opinion Letter June 14, 1993

Power strips used for surge protection or extra outlets

An OSHA safety committee asked when workplace power strips violated electrical rules. OSHA distinguished devices used for surge suppression from strips used solely to add convenient outlets, which…

Opinion Letter June 11, 1993

Backup alarms on industrial trucks at maritime worksites

A maritime employer asked whether powered industrial trucks needed backup alarms. OSHA said the cited maritime and general industry rules did not expressly require an alarm, but existing alarms…

Opinion Letter June 10, 1993

Lockout and radiation hazards at television towers

A state attorney general asked whether OSHA’s lockout rule applied to television transmission towers. OSHA said the telecommunications rule left other applicable standards in force and that lockout…

Opinion Letter June 9, 1993

Permanent job changes and restricted-workday counts

An employer asked when to stop counting restricted days on the former injury log. OSHA said a permanent modified assignment ended the count once the worker could perform all duties of the new job,…

Opinion Letter June 7, 1993

Recording bloodborne pathogen exposure incidents

A gas industry association asked when bloodborne pathogen exposure incidents had to be logged. OSHA said incidents were evaluated as injuries and became recordable with specified work consequences,…

Opinion Letter June 7, 1993

Forklift use in combustible dust atmospheres

A state labor official asked whether an ordinary powered industrial truck could dump hexamine where combustible dust clouds might form. OSHA said the described operation violated the cited…

Opinion Letter June 3, 1993

Process hazard analysis deadlines with one or two covered processes

An employer asked how process hazard analysis percentage deadlines applied at sites with just one or two covered processes. OSHA said a single covered process generally had to be analyzed in full by…

Opinion Letter June 3, 1993

Revised first-aid response times for construction sites

A construction employer asked how near medical help needed to be. OSHA revised its earlier answer, saying first aid should begin within three to four minutes where life-threatening injuries were…

Opinion Letter June 2, 1993

Bloodborne pathogen coverage for ear-piercing workers

An OSHA region asked whether ear-piercing workers were covered by the bloodborne pathogens rule. OSHA said blood contact during piercing was part of their main job, and employers had to evaluate the…

Opinion Letter June 2, 1993

Physical qualifications for crane operators

An equipment operator asked whether physical requirements printed in an OSHA training manual barred him from crane work. OSHA said those criteria came from an older consensus standard and that its…

Opinion Letter June 1, 1993

Western Growers Assurance Trust as a MEWA

A requester asked whether a California growers' health trust escaped MEWA status because some benefits appeared in union contracts. EBSA found the employer-controlled trust could set prices and…

Opinion Letter May 28, 1993

Transfer of terminated truckdrivers legal-plan assets

Counsel for jointly administered labor-management trusts asked whether a terminated legal-services plan could transfer excess assets to a related welfare plan. EBSA said shared trustees alone do not…

Opinion Letter May 28, 1993

Recording occupational bloodborne pathogen exposure incidents

An employer asked when a bloodborne pathogen exposure belongs on its injury log. OSHA said contact with non-intact skin or mucous membranes may be recordable when it results in specified…

Opinion Letter May 27, 1993

Fire extinguisher training and incipient fire brigade monitors

A chemical facility asked about extinguisher training and whether its incipient stage fire brigade could use large water monitors. OSHA said the described annual training met the extinguisher…

Opinion Letter May 27, 1993

Bloodborne pathogen precautions in organized sports

A sports medicine physician proposed precautions for bleeding athletes. OSHA said employers must identify workers with occupational exposure, agreed that trainers and team physicians would have…

Opinion Letter May 27, 1993

Recording bloodborne pathogen injuries on the OSHA 200 Log

An industry association asked when bloodborne exposure should be entered on the OSHA 200 Log. OSHA said an exposure to mucous membranes, non-intact skin or through the skin was recordable when it…

Opinion Letter May 24, 1993

Recording an injury during business trip recreation

An employer asked whether to keep a snowmobiling injury from a business trip on its OSHA 200 Log. OSHA said the answer depended on whether the activity involved transacting or promoting business; if…

Opinion Letter May 24, 1993

Recording burns and antiseptic treatment

An employer asked when burns and treatment with antiseptics were recordable on the OSHA 200 Log. OSHA said non-pinhead second degree and all third degree work-related burns were recordable…

Opinion Letter May 24, 1993

Recording cumulative trauma disorders on the OSHA 200 Log

An employer asked whether an employee’s stiffness should be recorded as a cumulative trauma disorder. OSHA said a subjective symptom without medical treatment, lost workdays or job transfer did not…

Opinion Letter May 24, 1993

Hatch Net fall protection and opening guards

OSHA sent its regional office a unified reply about a proposed hatch safety net. The attached letter said then-current opening rules required guards or covers, so the net was not equivalent…

Guidance May 21, 1993

Distributing the UCFE agricultural-board coverage ruling to tax and appeals staff

ETA told state agencies to give the UCFE agricultural-board coverage ruling from UIPL 23-92 to tax and appeals staff, who had been omitted from the original distribution. It repeated that employees,…

Guidance May 20, 1993

Transfer of terminated carpenters legal-fund assets

Carpenters fund trustees asked whether a terminated legal-services plan could move its remaining assets to a related welfare fund. EBSA said common trustees alone do not make plans parties in…

Opinion Letter May 18, 1993

Transfer of Alaska laborers legal-fund assets

A requester asked whether a terminated Alaska legal-services fund could transfer remaining money to a related health and welfare fund. EBSA said the plans were not parties in interest merely because…

Opinion Letter May 18, 1993

OSHA jurisdiction over injuries to members of the public

A person asked OSHA for help with an injury claim involving a moving company. OSHA said its statute addresses employer duties to employees at work, not injuries to members of the public caused by…

Opinion Letter May 18, 1993

Recording fractures, burns, eye injuries and treatment

An employer asked about several injury recording situations. OSHA described when fractures, second degree burns, eye treatment and repeated heat or cold therapy were recordable under its…

Opinion Letter May 17, 1993

Hazard communication labels for fire extinguishers

A fire protection company asked whether hazardous chemical labeling rules applied to fire extinguishers. OSHA said extinguishers containing hazardous chemicals, including compressed gas, required…

Opinion Letter May 15, 1993

Alternative methods for Benefits Quality Control investigations

ETA directed state agencies to begin using revised methods for Benefits Quality Control investigations in July 1993. It retained in-person claimant interviews and generally in-person work-search…

Guidance May 13, 1993

Hazard communication coverage of drugs in veterinary work

A lawmaker asked how the Hazard Communication Standard applied in veterinary practices. OSHA said hazardous drugs and chemicals are covered, with exceptions for certain retail consumer packages,…

Opinion Letter May 11, 1993

Generic safety data sheets for fertilizer mixtures

A consultant asked whether fertilizer makers needed a separate material safety data sheet for every nutrient combination. OSHA said a generic sheet could cover mixtures with the same hazards if it…

Opinion Letter May 7, 1993

Process safety coverage of flammable spray painting

A manufacturer asked whether flammable paint used in spray operations triggered process safety management. OSHA said covered operations depended on the 10,000 pound threshold and how a process or…

Opinion Letter May 6, 1993

Employer premium trust and medical plan assets

An employer asked whether money it set aside in a revocable premium trust belonged to its employee medical plan. EBSA said the separate policy trust and insurance policy were plan assets, but the…

Opinion Letter May 5, 1993

Disposal of toenail debris in podiatry practices

A podiatrist asked whether toenail particles and dust required regulated waste disposal. OSHA said particles are potentially infectious only if contaminated with blood or other specified material.…

Opinion Letter April 30, 1993

Disinfectant exposure and bloodborne pathogen duties

A dental safety consultant raised concern that increased disinfectant use could expose workers to chemicals. OSHA said the bloodborne pathogens standard required suitable decontamination and that…

Opinion Letter April 30, 1993

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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.

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