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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Hospital hazardous release response and HAZWOPER training
A hospital council asked when a spill counted as an emergency under HAZWOPER and what staff training was required. OSHA said the distinction depended on hazard and response conditions, not just…
Directed trustee purchases of bank parent stock
A bank serving as directed trustee asked whether client plans could buy its parent company’s stock through unrelated brokers. EBSA said blind exchange trades ordered by an unaffiliated named…
Employee access to OSHA injury and illness logs
An employee asked about access to injury records and whether an earlier workplace injury should have appeared on an OSHA log. OSHA said employees and former employees could inspect the log for an…
Pooled reinsurance health program as a MEWA
A requester asked whether an administrator's supposedly separate employer health programs were one multiple employer welfare arrangement. EBSA said pooled reinsurance payments and benefit claims…
Recording hearing loss, burns and falls on injury logs
A company physician asked when hearing loss, burns and falls were recordable. OSHA described a work-relatedness presumption for hearing loss after workplace noise exposure and the evidence needed to…
Consumer product use under hazard communication in a medical office
A physician questioned OSHA's bloodborne pathogen and hazard communication requirements for medical offices. OSHA said a consumer cleaning product could fall under hazard communication when…
Exposure control plans and protective equipment in medical offices
A senator relayed a physician's concerns about the bloodborne pathogens rule. OSHA said an exposure control plan need not be lengthy or professionally produced, but must contain the elements…
Changes in Reporting Unemployment Compensation Benefit Payments--Department of Commerce and Bureau of the Census
ETA directed state agencies to report unemployment benefit payments for former Census employees made after September 30, 1992 under the Department of Commerce agency code, while retaining the Census…
Twenty injury and illness recordkeeping questions
A safety consultant asked twenty questions about recording workplace illnesses and injuries, including chemical exposure, stress, off-duty time and first aid. OSHA gave case-specific answers under…
OSHA's worker safety jurisdiction over bungee jumping
A bungee jumping operator asked about OSHA policy for the activity. OSHA said its statutory concern was worker safety, while customer and bystander safety belonged to state and local authorities. It…
Process safety coverage for propane filling and delivery
A gas supplier asked whether propane filling sites and delivery trucks counted under the process safety management rule. OSHA said the described customer filling sites appeared exempt as retail…
Fixed building ladders during construction
An engineering company asked which OSHA ladder rule applied to permanent fixed ladders installed in a building while construction continued. OSHA said the construction stairway and ladder rule was…
Discarded feminine hygiene products and regulated waste
An employer asked whether discarded feminine hygiene products were regulated waste under OSHA's bloodborne pathogens rule. OSHA said they generally were not, because their absorbent material…
Scaffold support system review and product endorsement policy
A manufacturer asked OSHA to review a roof scaffold support system. OSHA said it does not approve or endorse products, because installation and jobsite conditions matter. Based on the information…
OSHA and EPA flammable liquid containment requirements
In a variance review, OSHA considered whether its flammable liquid containment rule conflicted with an EPA emergency requirement. OSHA said both addressed keeping releases away from ignition sources…
Airborne radioactivity areas under OSHA's radiation rule
A state radon program asked when OSHA's ionizing radiation rule required posting an airborne radioactivity area. OSHA said the rule could cover naturally occurring radioactive material and used the…
First aid staffing and bloodborne pathogen coverage
An employer asked whether it needed trained first aid staff and whether those workers came under the bloodborne pathogens rule. OSHA said the first aid rule did not itself require formally assigning…
First aid proximity, designated aiders, and bloodborne pathogen coverage
A safety technician asked when first aid training and bloodborne pathogen protections are required. OSHA said first aid training is unnecessary if medical or emergency help can reach workers within…
First aid requirements for offices and multiple locations
A consultant asked whether OSHA's first aid rule applied to offices, small employers and companies with multiple locations. OSHA said the rule covered general industry employers regardless of size,…
Needle resheathing device and two-handed recapping protection
A medical device company asked whether its needle resheathing device met OSHA's bloodborne pathogens rule. OSHA said the device did not adequately protect the hand holding it from accidental…
Bloodborne pathogen rule for oil drilling first aid
An oil drilling trade group asked whether its industry was covered by the bloodborne pathogens standard. OSHA said coverage depended on an employee's reasonably anticipated contact with blood during…
Bloodborne pathogen duties for temporary nurse staffing agencies
A temporary nurse staffing company asked how OSHA's bloodborne pathogens rule applied when nurses worked at client hospitals. OSHA said both employers shared responsibility: the hospital controlled…
Pole strap positioning devices for climbing wood poles
A safety specialist asked whether body belts and pole straps could protect workers climbing wooden transmission poles. OSHA said a short positioning strap could serve as fall protection during…
Bloodborne pathogen protection for summer camp workers
A camping association asked which summer camp and retreat workers were covered by OSHA's bloodborne pathogens rule. OSHA said the answer turned on assigned duties with reasonably anticipated blood…
FCE health and welfare trust as a MEWA
Virginia regulators asked whether a health trust for workers of multiple service employers was a MEWA. EBSA said the trust provided benefits across employers and did not fit a statutory exception,…
Richmond police association welfare and pension benefits
A police benevolent association asked whether public supporters made it something other than an employee organization and whether its benefits were only welfare benefits. EBSA said active police…
Simmons short-term disability pay as payroll practice
An employer asked whether its proposed short-term disability plan was an ERISA welfare plan. EBSA said payments during disability, funded from the employer’s general assets and capped at normal…
Glove use when subculturing organisms from blood
A microbiology group asked whether laboratory staff always needed gloves when handling organisms subcultured from blood. OSHA said glove use under the bloodborne pathogens rule depended on…
Dental office compliance checklist and OSHA endorsement
A dental association asked OSHA to confirm that following its proposed checklist would put dental offices in substantial compliance. OSHA declined to endorse that claim, saying compliance depends on…
Medical record retention and chemical labels in dental offices
A senator relayed a dentist's questions about the bloodborne pathogens rule. OSHA said employee medical records documenting vaccination and exposure follow-up had to be kept for the required period…
Recording bloodborne pathogen exposures and worker privacy
A public health department asked to use coded worker identifiers on injury logs to protect privacy. OSHA denied the variance under its then-current recordkeeping system and explained when bloodborne…
Eye foreign-body removal as first aid or medical treatment
A medical worker asked when removal of foreign material from an eye or eyelid made an injury recordable. OSHA said removing embedded material from the eye was medical treatment, while irrigation or…
HAZWOPER at hazardous waste generators and manufacturing sites
A manufacturer asked how HAZWOPER applied to emergency releases and short-term hazardous waste storage. OSHA said the emergency response provisions could cover hazardous substance releases…
Training construction workers who use Level 1 lasers
A carpenters' safety fund asked what training OSHA required for workers using Level 1 lasers. OSHA said the construction laser rule required training even for those devices, with general safety…
JTPA Title III eligibility for former armed forces members
ETA explained how state job-training agencies should assess former service members for JTPA Title III dislocated-worker programs. It said involuntary separation, possible eligibility for…
Steel erection fall protection and construction subparts
A construction safety council asked how OSHA's then-current rules treated falls during steel erection and whether construction Subpart B applied generally. OSHA distinguished interior from exterior…
Protective equipment for hospital hazardous substance response
A university safety official asked whether hospital personnel treating victims of hazardous releases always needed Level A protective equipment. OSHA said Level A applied where skin absorption could…
Portable GFCI extension cords for construction circuits
A telephone company asked whether GFCI-protected extension cords satisfied OSHA's construction branch circuit rule. OSHA said approved portable GFCIs were acceptable protection under the cited…
Bloodborne pathogen rule for grocery first aid staff
A food retail association asked whether the bloodborne pathogens rule covered grocery stores and wholesalers. OSHA said coverage depended on assigned work with reasonably anticipated blood contact,…
Decompression tables for commercial diving
A correspondent asked which decompression tables OSHA accepted for commercial diving in the United States. OSHA said its diving standard allowed either the U.S. Navy Diving Tables or equivalent…
Machine guarding and lockout for printing presses
A printing industry association asked when machine guarding rules or lockout rules applied to printing presses. OSHA said guarding covered normal production, while servicing that exposed workers to…
Hearing shifts and self-administered care on injury logs
A state labor official asked how employers should record hearing shifts and several borderline treatment cases. OSHA said an employer could keep earlier 10-decibel hearing shift entries under its…
Bloodborne pathogen labels, needle recapping and uniforms
A hospital asked about labels for contaminated laundry, needle recapping in psychiatric units and employer laundering of uniforms. OSHA said alternate laundry coding still had to alert workers to…
HAZWOPER field experience and refresher training
A hazardous waste contractor asked whether three days of field experience had to occur on a government-listed site and whether overseas workers could complete refresher courses by correspondence.…
Medical records and contaminated laundry under the bloodborne rule
A senator relayed a physician's concerns about bloodborne pathogen compliance. OSHA said required employee medical records could be held by a health professional if the employer ensured OSHA could…
Worker transfers between fishing vessels by personnel basket
A regional administrator asked whether earlier OSHA guidance allowed a personnel basket to move workers between fishing vessels. OSHA corrected its earlier implication that no standard addressed the…
Eyewash fountain testing and hot water hazards
An OSHA regional administrator asked about a particular eyewash fountain under the emergency washing rule. OSHA said an accepted testing laboratory's favorable ANSI test could show a product met a…
Bloodborne pathogens requirements and costs for dental offices
A member of Congress relayed a dentist's concerns about the need for and cost of OSHA's bloodborne pathogens rule. OSHA explained the rule's public process and cost analysis, and said worker…
Bloodborne pathogen rule for oilwell service first aid
An oilwell service association asked whether OSHA's bloodborne pathogens rule applied outside health care. OSHA said employees assigned to provide first aid could have reasonably anticipated blood…
Utility work at hazardous waste sites under HAZWOPER
A state safety commissioner asked whether utility crews working at a hazardous waste site before cleanup began were covered by HAZWOPER. OSHA said they were covered when contamination was expected…
Recording a blood exposure outside designated first aid work
A company asked whether a blood exposure involving a worker who was not a designated first responder belonged on its OSHA injury log. OSHA said recordkeeping and the bloodborne pathogens rule had…
Bloodborne pathogen training content for first aid responders
The American Red Cross asked whether a general infectious disease guide satisfied OSHA's bloodborne pathogen training rule for workplace first aid responders. OSHA said the material could cover some…
Bloodborne first aid duties in utility construction and maintenance
A senator asked how OSHA's bloodborne pathogen rule applied to electric utility employees who might give first aid. OSHA said training alone did not trigger coverage; assigned first aid duties with…
Eating and drinking at nurses' stations under the bloodborne rule
A senator asked why nurses could not drink at their stations. OSHA said the bloodborne pathogens rule barred eating and drinking where work could involve blood exposure or contamination of surfaces,…
Protective equipment for residential care workers
A congressman asked whether employees providing residential services to people with developmental disabilities needed bloodborne pathogen protection. OSHA said employers had to identify jobs with…
HAZWOPER coverage for university waste facilities and spills
A university asked whether its entire campus fell under HAZWOPER because of a waste facility permit and when laboratory spills required emergency response. OSHA said the treatment and storage…
Lost workday counts after an injured employee is terminated
An employer asked how to document stopping lost workday counts when an injured employee left. OSHA said an unrelated termination could stop the count, with documentation of the circumstances helpful…
Separate injury logs for each residential care home
A residential care organization asked how to apply OSHA's former injury and illness log rules. OSHA said workers' compensation decisions did not determine whether a case belonged on its log. Because…
Recordkeeping tests, aggravation and phobia symptoms
A chemical company asked several questions about its injury and illness log. OSHA said a test result within expected normal variation did not itself establish an abnormal condition, and discussed…
Consolidation of the Attachments to GAL 4-92 Incorporating GAL 4-92, Changes 1 Through 4
ETA supplied a consolidated version of the Emergency Unemployment Compensation instructions from GAL 4-92 and its first four changes, calling the attached instructions controlling guidance for…
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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.