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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ADA bloodborne compliance checklist does not assure compliance
OSHA clarified that its limited review of an American Dental Association checklist did not approve the checklist or promise that a dental office using it would comply with the bloodborne pathogens…
Larger chest X-ray film under OSHA standards
A testing provider asked if 16-by-17-inch chest X-ray films remained acceptable where OSHA rules specified 14-by-17-inch film. OSHA reaffirmed its earlier position that the larger format was…
Bloodborne pathogens rule for small medical offices
A physician questioned the cost and complexity of the bloodborne pathogens standard for small medical offices. OSHA described the bloodborne risks to health care workers, the rule's development and…
Daylight blasting rule inside a contained vessel
A contractor asked whether it could blast hardened material inside a furnace vessel before dawn. OSHA said the sunup-to-sundown requirement addressed outdoor blasting, where daylight helps keep…
Intra-Title II transfers of JTPA funds
ETA explained how service delivery areas could use remaining Title II-A funds for 1993 activities and transfer limited amounts among Title II program parts with a governor's approval. It described…
Approval requirements for electrical conductors and equipment
A lawyer asked how OSHA’s electrical equipment approval rule involves nationally recognized testing laboratories. OSHA said electrical conductors and equipment used to safeguard employees must be…
Long-term restrictions, geographic scope and work-related injury logging
An employer asked eight questions about OSHA 200 Log entries, including permanent job modifications, travel into the United States, self-administered treatment, chipped teeth and days away from…
Recording work-related falls and cumulative trauma symptoms
An employer asked whether to log an employee’s head cut after fainting from a vitamin reaction and another employee’s wrist symptoms after computer work. OSHA said the fall injury was recordable…
JTPA amendments and modifications to state coordination plans
ETA told governors how to update their JTPA coordination and statewide job training plans for the 1992 amendments. It identified required changes to oversight, program coordination, resource use and…
Handling sterile and contaminated medical instruments in operating rooms
An operating room director asked whether OSHA forbids passing sharp instruments directly between staff. OSHA said the bloodborne-pathogens standard does not regulate sterile instruments, so…
Bloodborne pathogens standard costs and personal protective equipment requirements
A physician raised concerns about the cost and scope of OSHA’s bloodborne-pathogens standard. OSHA said the personal protective equipment requirement is performance based: employers may select gear…
Rope ladder access to sheet pilings during construction
A construction company asked whether a rope ladder could provide access to the top of sheet pilings during installation. OSHA’s national office said the described use would comply if the safeguards…
Ammonia solutions covered by the Process Safety Management standard
A chemical company asked whether the Process Safety Management listing for ammonia solutions above 44 percent by weight also covers ammonium chloride or ammonium bisulfite solutions. OSHA said the…
Reallotment of 1992 JTPA Title III formula funds
ETA told states how it recaptured excess unspent JTPA Title III funds and reallotted them for program year 1992. Its attached Federal Register notice explains the formula and lists the change for…
Annual bloodborne pathogen training frequency
A congressional office asked whether the bloodborne pathogens rule required Red Cross volunteers to take five hours of training every ninety days. OSHA said that was incorrect: covered workers…
Hepatitis B vaccination series follow-up under the bloodborne pathogens standard
A clinical laboratory asked how closely it had to monitor employees completing hepatitis B vaccinations. OSHA said employers need good-faith reminders, not extraordinary efforts, and employees may…
Bloodborne pathogens standard: frequently asked questions
OSHA answers 80 questions about the bloodborne pathogens standard, including who is covered and what employers must do for exposure controls, vaccination, training, and records. The FAQ says it does…
Inspection and certification of cranes at construction sites
A crane company asked whether federal OSHA required certification stickers from an accredited maritime agency for cranes on a construction site. OSHA said its rules then required competent-person…
Hospital respiratory protection for routine exposures and chemical emergencies
A hospital safety supervisor asked about respirators for routine ethylene oxide and formaldehyde exposure and for spills or leaks. OSHA said routine respirators were not needed if sampling showed…
Injury and illness recordkeeping requirements for sheltered workshops
A state labor official asked whether sheltered workshops had to keep OSHA injury and illness logs. OSHA said workshops properly classified under SIC 8331 were exempt unless the Bureau of Labor…
Ammonia refrigeration emergency response training
A plant operator asked how HAZWOPER emergency response training applied to maintenance workers and contractors at an ammonia refrigeration site. OSHA said expected responders needed training for…
HAZWOPER coverage of clean support-zone staff
A hazardous waste site employer asked if administrative employees in a monitored clean support zone needed HAZWOPER training. OSHA said they were outside the rule under the described facts because…
Counting contaminated laundry away from patient rooms
A linen service asked whether its route workers could count soiled health-care textiles before bagging them. OSHA said the rule barred sorting at the location of use but did not prohibit counting in…
Two-handed needle recapping device review
A dentist asked if a proposed device could be used to recap contaminated needles. OSHA said recapping was allowed only for specified medical need or infeasibility of alternatives, and then required…
Bloodborne exposure for hotel housekeeping staff
A safety consultant asked whether hotel housekeepers were covered by the bloodborne pathogens rule. OSHA said non-health-care housekeeping was not generally covered, but employers had to assess…
Disinfectants for blood-contaminated surfaces
A disinfectant supplier asked what products met OSHA's bloodborne pathogens decontamination rule. OSHA said EPA regulated product registration, while OSHA required an appropriate disinfectant for…
Blood-contaminated evidence and protective gear decontamination
An OSHA region asked how blood-soaked evidence and protective gear could be handled under the bloodborne pathogens rule. OSHA discussed closed containers, possible infeasibility or variance…
Bloodborne pathogen protection in construction and maintenance
A health service asked whether construction workers with blood exposure had to receive hepatitis B vaccination. OSHA said its bloodborne pathogens rule did not apply to construction work but could…
Hydrochloric acid solutions under the Process Safety Management standard
A manufacturer asked whether OSHA’s Process Safety Management listing for hydrogen chloride covered a 37 percent hydrochloric acid solution. OSHA said Appendix A listed hydrogen chloride and…
Military pay schedule for unemployment claims by ex-servicemembers
ETA directed state unemployment agencies to use the attached military pay schedule to determine federal wages for UCX first claims beginning with the first week after April 3, 1993. Earlier first…
Aqueous hydrochloric acid and PSM chemical listing
A manufacturer asked if a 37 percent hydrochloric acid solution was covered by OSHA's process safety management rule. OSHA said the Appendix A listing covered hydrogen chloride in its anhydrous…
Review of Reeves Sleeve stretcher for emergency rescue
A supplier asked OSHA to review a particular emergency rescue stretcher. OSHA said it does not approve or endorse products, but the device appeared capable of meeting a construction emergency rescue…
Rigging rule applies to pulling loads
A shoring company asked whether OSHA's construction rigging rule applied when rigging equipment pulled rather than lifted a load. OSHA said 29 CFR 1926.251 applied whenever the equipment was used to…
Hazardous waste transport and HAZWOPER response training
A senator asked about rules for handling and transporting hazardous waste. OSHA said HAZWOPER did not cover vehicle operators merely as drivers, but operators expected to respond to a transport…
The Treatment of Emergency Unemployment Compensation (EUC) Cases in Unemployment Insurance (UI) Quality Control (QC)
ETA told state agencies how to treat unemployment insurance payments that later become Emergency Unemployment Compensation payments because a claimant elects that program. Such payments were not to…
Sacred Heart Medical Center pension as a church plan
A requester acting for the Bernardine Sisters asked whether the retirement plan for Sacred Heart Medical Center employees was a church plan. EBSA said the religious order's control of the center and…
AAA Michigan disability pay as payroll practice
An employer asked whether its disability income replacement program became an ERISA welfare plan after changing how payments were administered. EBSA said benefits paid exclusively from the…
OSHA injury and illness reporting and workers compensation data
A museum suggested OSHA obtain injury and illness data from workers compensation carriers instead of employer records. OSHA said those data were likely incomplete and lacked some information the OSH…
Flammable liquid storage and the Process Safety Management exemption
Two trade associations asked whether the PSM exemption covered all flammable liquids kept below their boiling point without refrigeration. OSHA said it applied to liquids in tanks, containers and…
Charlotte Mercy Hospital pension as a church plan
A North Carolina Mercy hospital asked whether its employee pension plan was a church plan. EBSA said the Catholic order’s control of the hospital and associated plan committee met the definition on…
Recording hearing loss when an employee works at multiple establishments
A regional office asked where a company should record an employee’s hearing loss after the employee had worked at two plants. OSHA said to log an illness at the establishment where the exposure…
Copper alloy material safety data sheets
A trade association asked OSHA to evaluate a generic material safety data sheet for copper alloys. OSHA said it did not approve such sheets; manufacturers and importers had to assess known or…
Use of the Interstate Telecommunication Network (INTERNET) to Send and Receive Request for Wage Transfers and Report on Determinations for Combined Wage Claims
ETA directed state unemployment agencies to stop using paper for specified combined-wage claim wage-transfer requests, responses, and determination reports starting April 5, 1993. States were to use…
Contract employees and injury and illness recordkeeping requirements
A bottling company asked who logs injuries and illnesses of workers supplied by a temporary help service. OSHA said the key factor was who supervised the workers’ daily methods and tasks. If the…
Correction to quality appraisal answer on nonmonetary determination promptness
ETA corrected the second answer attached to UIPL 10-93. When a potential issue is detected before the claimant certifies for the affected week, states should start the nonmonetary determination…
HAZWOPER cleanup and emergency training handout corrections
A worker safety committee asked OSHA to review a HAZWOPER handout. OSHA did not endorse it but gave detailed corrections about site coverage, worker training, emergency release criteria, response…
Hazard communication for medications in care facilities
A long-term care association asked whether FDA-regulated medications were exempt from OSHA's hazard communication rule. OSHA said a court had rejected the prior broad exemption, so hazardous drugs…
HAZWOPER completion certificates and field experience
A training college asked whether a certificate of attendance met HAZWOPER requirements. OSHA said instructors had to assess successful completion of the training objectives and certify it, and…
Area classification drawings for petrochemical plants
A requester asked whether OSHA required area classification drawings under industry electrical standards. OSHA said it did not require or enforce those drawings, though its hazardous-location…
Hazard communication for resident-supplied medications
A long-term care operator asked how the hazard communication rule applied when residents obtained prescriptions from outside pharmacies. OSHA said it covered foreseeable hazardous drugs used by…
Additional warrant officer pay grade for the 1992 UCX remuneration schedule
ETA added the W-5 warrant officer pay grade to the 1992 military remuneration schedule used for unemployment claims by former service members. It supplied a complete revised schedule for state…
Hazard communication exceptions for dermatology products
A dermatology group asked whether patch test kits and several office and consumer products were exempt from hazard communication duties. OSHA said FDA-labeled kits could be exempt from OSHA's label…
Use of JTPA six percent funds for information system redesign
ETA allowed states and local service delivery areas to use certain JTPA technical assistance and incentive funds to update their management information systems for new participant reporting and…
Lockout and tagout duties for contractors at electric utility sites
An insurer asked how OSHA’s lockout and tagout rule applied to contractors at electric utility sites. OSHA said the 1910.147 exclusion for certain utility installations also covered contractors…
HAZWOPER monitoring in clean zones of cleanup sites
An OSHA office asked how HAZWOPER monitoring applied to areas labeled clean at a larger hazardous waste cleanup site. OSHA said coverage depended on potential exposure, including changed conditions…
Bloodborne pathogens rule and construction work
A construction labor group challenged OSHA's decision not to apply its bloodborne pathogens standard to construction work. OSHA explained that construction had not received notice during rulemaking,…
Air Force separation reason after early release
ETA clarified when an Air Force separation reason used during an early release program should affect UCX eligibility. Current status is unconfirmed.
Where employers obtain material safety data sheets
An employer asked OSHA to send updated material safety data sheets. OSHA said it did not provide them; manufacturers, importers, and distributors had to send required sheets to downstream users, and…
Hazardous chemical inventory in a medical office
A physician asked how to list office chemicals and the hazards of each ingredient. OSHA said the workplace inventory should list hazardous chemical identities matching the safety data sheets; it did…
Hepatitis B opinions and contaminated laundry duties
A long-term care association asked six questions about the bloodborne pathogens rule. OSHA explained when a health care professional's written opinion was required for hepatitis B vaccination,…
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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.