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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Fit testing and reuse of single-use respirators
A correspondent asked whether South Carolina's treatment of single-use respirators matched federal OSHA policy. OSHA said federal policy required fit testing when a worker first selected one and…
Meat industry questions on HAZWOPER and bloodborne hazards
A meat industry group asked how several OSHA rules applied to its plants. OSHA said emergency response training for ammonia releases depended on whether workers were expected to respond to a…
Gloves for routine injections under the bloodborne rule
An allergy clinic asked whether staff needed gloves for routine injections. OSHA said the bloodborne pathogens rule required gloves when hand contact with blood or other infectious material was…
Reusable sharps containers versus disposable sharps waste
A dental infection control consultant asked whether a reusable instrument cassette had to meet a rule for automated cleaning of containers holding discarded sharps. OSHA said that cited requirement…
Employee access to chemical safety data sheets
A congressman asked how a former worker could get a material safety data sheet for a chemical exposure. OSHA said makers and importers had to send sheets to downstream employers for workplace…
Bloodborne pathogen duties for non-health care first aid staff
A senator asked whether the bloodborne pathogens rule applied to employees giving first aid outside health care. OSHA said designated first aid duties with reasonably anticipated blood contact…
Task-based protective equipment in residential disability care
A congressman relayed concern that protective equipment for residential disability care could be perceived as discriminatory. OSHA said coverage turned on employees' reasonably anticipated contact…
Minimum HAZMAT technician training hours and competency
A worker safety group asked whether a 24-hour HAZMAT technician course was enough under HAZWOPER. OSHA said the stated hours were a minimum and technicians also had to master the listed…
Bloodborne pathogen coverage and retail industry variance request
A retail trade group sought relief from the bloodborne pathogens standard. OSHA said designated first aid providers with anticipated blood contact could be covered, while merely training someone in…
Bloodborne pathogen protection at a school for disabled students
Parents asked whether OSHA's bloodborne pathogens rule required staff at their child's school to wear protective gear during ordinary care. OSHA said the rule protected workers with reasonably…
No OSHA infection control kit rule for school buses
A senator asked whether schools receiving federal funds had to put infection control kits on buses. OSHA said its bloodborne pathogens rule addressed employee protection where workers had…
Eating and drinking in medical waiting rooms
A senator asked whether OSHA barred patients from eating or drinking in a doctor's waiting room. OSHA said its rule applied to employees in work areas with blood exposure or contaminated surfaces,…
Annulment order and pension alternate payee status
A pension fund asked how to treat an annulment order awarding benefits to a former spouse. EBSA said that, if a competent Michigan court entered the order under state domestic relations law, the…
Atmospheric tank storage under the process safety rule
A chemical company asked whether flammable liquids kept in atmospheric tanks above the threshold quantity were outside the process safety rule. OSHA said the storage method alone did not establish…
Pole straps as fall restraint while climbing power poles
A safety consultant asked whether a worker could use a body belt with a pole strap while climbing a power pole if the belt maker barred fall arrest use. OSHA said the combination was an acceptable…
Protective equipment and vaccination duties in nursing homes
A nursing home representative asked about protective equipment, vaccination and costs under the bloodborne pathogens rule. OSHA said employers could choose suitable barriers for actual task…
Construction coverage and red bags for contaminated laundry
A safety consultant asked about construction coverage under the bloodborne pathogens rule and labeling laundry sent offsite. OSHA said its then-current policy excluded construction work because the…
Unemployment Compensation Amendments of 1992 (P.L. 102-318) - Provisions Affecting the Federal-State Unemployment Compensation (UC) Program
ETA explained to state unemployment agencies how the Unemployment Compensation Amendments of 1992 changed the federal-state program, including Extended Benefits triggers, financing, coverage, and…
Inspection access to federally funded highway projects
OSHA told regional administrators how to document entry rights for inspections of federally funded highway projects. The Federal Highway Administration planned to add express inspection language to…
Hoist rope connections and sling latches in construction
A joint venture asked whether a construction hoist rope connection standard also governed slings and required locking latches. OSHA said that provision addressed only the hoist rope connection;…
Designated first aid duties under the bloodborne pathogen rule
A physician asked OSHA to narrow coverage of the bloodborne pathogens rule to workers with a significant risk. OSHA said first aid training alone did not bring a worker under the standard; assigned…
Site-specific HAZWOPER plans with multiple contractors
A hazardous waste contractor asked whether an EPA computer plan could replace its own site safety plan and who should write a plan for a site with several employers. OSHA said HAZWOPER required…
Contaminated needle melting device and bloodborne pathogens rule
A company asked OSHA whether a device that melts used injection needles satisfied the bloodborne pathogens rule. OSHA said it does not approve products in the abstract and must consider how they are…
EUC questions after the Unemployment Compensation Amendments of 1992
ETA answered state agency questions arising from the 1992 amendments to the emergency unemployment compensation program. It addressed how claimants could elect emergency benefits or regular…
Bloodborne pathogen rule excludes construction work in 1992
A senator asked whether construction workers were covered by the new bloodborne pathogens standard. OSHA said it was changing its enforcement instruction to exclude construction work as then…
Employer-paid HAZWOPER training and medical surveillance
A senator asked about training and medical requirements for hazardous waste workers. OSHA said employers had to provide required HAZWOPER training without charging workers and pay workers during…
Bloodborne pathogen coverage for maintenance trades
A construction association asked whether employees doing maintenance were covered by the bloodborne pathogens rule. OSHA said maintenance workers with reasonably anticipated contact with blood or…
HAZWOPER training after site characterization
An EPA official asked whether some tasks at a Superfund site could be excluded from HAZWOPER training. OSHA said ongoing site characterization had to show no exposure or reasonable possibility of…
Safety syringe products and OSHA compliance review
A device designer asked OSHA to review safety syringes and disposal fixtures under the bloodborne pathogens rule. OSHA said it does not endorse products or decide compliance from a device alone.…
Handwashing after glove removal for phlebotomists
A physician asked OSHA to waive handwashing after phlebotomists removed gloves that showed no visible blood. OSHA declined, saying the bloodborne pathogens standard expressly required handwashing…
Required wording for hepatitis B vaccine declination
A hospital asked OSHA to review its hepatitis B vaccine consent form and policy. OSHA declined to endorse the local documents but said the standard's Appendix A contained mandatory wording for a…
Patient-safety devices and bloodborne pathogens rule coverage
A health care consultant asked OSHA to assess purification and sterilization equipment under the bloodborne pathogens rule. OSHA declined to endorse the equipment and said compliance depends on…
Bloodborne pathogen coverage for hotel laundry workers
A hotel asked whether housekeepers and laundry workers were covered by the bloodborne pathogens rule. OSHA said their jobs were not automatically covered; the employer had to assess tasks from linen…
Resident vaccination and protective gowns in care facilities
A senator asked whether vaccinating residential care clients could replace employee vaccination and other bloodborne pathogen protections. OSHA said it could not, because screening and vaccination…
Employee identifiers in bloodborne exposure medical records
A physician asked whether the bloodborne pathogens rule could require Social Security numbers in employee medical records. OSHA said its then-current recordkeeping provision expressly required each…
Competent person presence at excavation sites
A construction employer asked whether an excavation competent person had to stay at the site at all times. OSHA said there was no blanket continuous-presence requirement. The person had to inspect…
Elements of a construction hearing conservation program
A construction company asked what counted as a hearing conservation program under OSHA's noise rule. OSHA listed exposure monitoring, controls, fitted protectors, worker training, baseline and…
Average Weekly Benefit Amount (AWBA) for Major Disasters that Occur During the Fourth Quarter of Fiscal Year (FY) 1992 (July 1 through September 30, 1992)
ETA directed states to use the attached average weekly benefit amounts when calculating disaster unemployment assistance for major disasters in July through September 1992. It said states should…
Needle recapping device and limited recapping exceptions
A company asked OSHA to review a syringe holder under the bloodborne pathogens rule. OSHA said it does not endorse products and that compliance depends on workplace practices as well as equipment.…
OSHA inspection, abatement and penalty procedures
A member of Congress asked how OSHA handles citations, deadlines, costs and equipment that does not meet safety standards. OSHA said its area director sets an abatement date based on the hazard and…
Bleach dilution for bloodborne pathogen decontamination
A university researcher asked whether household bleach could be used to disinfect surfaces under OSHA's bloodborne pathogens standard. OSHA said 5.25 percent sodium hypochlorite diluted between 1:10…
Formaldehyde concentration under process safety management
A chemical company asked what formaldehyde concentration OSHA meant in the process safety management rule's Appendix A. OSHA said the listing should read formaldehyde at 37 percent by weight or…
Spray painting in vehicle maintenance operations
A vehicle maintenance employer asked when spray painting a truck indoors or outdoors was permitted. OSHA said indoor spraying had to meet the applicable spray finishing requirements, including…
Confidentiality under the bloodborne pathogens standard
An inquiry asked about confidentiality after occupational exposure to bloodborne pathogens. OSHA said exposed workers' blood could not be collected or tested for HIV or hepatitis B without consent,…
Bloodborne pathogens coverage of electric utility first aid
An electric utility asked which first aid workers fall under OSHA's bloodborne pathogens standard. OSHA said workers designated to give first aid as part of their duties were covered because…
New Jersey tooling association health plan as a MEWA
A requester asked whether a New Jersey trade association's health program for about 90 employers was a multiple employer welfare arrangement. EBSA said it was a MEWA and ERISA did not bar state…
Separate HAZWOPER supervisor and annual refresher training
A hazardous waste employer asked whether eight hours of supervisor training could also count as a worker's annual eight-hour refresher. OSHA said a worker becoming a supervisor should receive at…
Fall protection for steel erection connection work
A safety consultant asked about fall protection for workers doing steel erection connection work. OSHA said that, under the policy and decisions it described in 1992, the general duty clause could…
Rollover protection for backhoe equipped tractors
A construction equipment maker asked OSHA to reconsider rollover protection requirements for tractors with backhoe attachments. OSHA said moving a tractor exposes the operator to rollover hazards…
Bloodborne pathogens coverage for first aiders and sewage line spills
An environmental consulting company asked whether designated first aiders and workers who accidentally rupture a sewage line were covered by OSHA's bloodborne pathogens standard. OSHA said workers…
Hard hats worn with the bill to the rear
A union representative asked whether construction workers could wear hard hats with the bill facing backward. OSHA said that under the cited head protection rule, this would not meet the ANSI…
Bloodborne pathogens protections for home health workers
A home health agency asked whether workers with a low but foreseeable exposure risk needed bloodborne pathogens training and an offer of hepatitis B vaccination. OSHA said employers must determine…
Small farm enforcement rider applied to nurseries
An OSHA regional administrator asked whether small nurseries qualify for the farming appropriations rider. OSHA said a qualifying employer needed ten or fewer employees, no temporary labor camp, an…
Backhoe work near overhead power lines
A utility contractors group asked whether insulating barriers alone could protect a backhoe working near overhead power lines. OSHA said barriers could be adequate if only brushing contact was…
Hepatitis B vaccination policy for collateral duty first aiders
A chemical company asked about OSHA's policy for workers who provide first aid only as a secondary duty. OSHA said those designated first aiders were covered by its bloodborne pathogens standard,…
HAZWOPER training for marine oil spill response
A marine claims office asked what training its workers and an attorney needed at oil spill sites. OSHA distinguished emergency response from later cleanup and said workers entering clean zones…
Scheduling annual HAZWOPER refresher training
A company asked whether it could provide HAZWOPER refresher training in segments through the year. OSHA said that was allowed if all refresher requirements were met, but the sessions should begin…
Bloodborne pathogens coverage for child care first aiders
A pediatric group asked how OSHA's bloodborne pathogens standard applies to child care workers. OSHA said employers must assess which duties foreseeably involve contact with blood or other…
Construction first aid, scaffolds, lifts and roof access
An OSHA training office asked eight questions about construction requirements. OSHA addressed first aid kits by shift, makeshift scaffold guarding, access ladders, scissor and boom lifts, roof fall…
Emergency eyewash and showers at construction sites
A construction safety program asked whether OSHA's emergency eyewash and shower rule applied at construction sites. OSHA said it did where workers could be exposed to injurious corrosive materials,…
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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.