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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Roll-over protection for older Cary-lift loaders
An equipment maker asked OSHA to update a 1972 roll-over protection letter by removing machine models it no longer manufactured. OSHA declined because older units might still be in service and…
Injuries at a required company picnic
An employer asked whether a worker's injury during sports at a company picnic belonged on its injury log. OSHA said required attendance made the off-site event work-related under its then-current…
Concealed damage to maritime cargo-handling gear
OSHA warned its regional staff that filler material could conceal structural damage on vessel or shore cargo-handling gear. It described a way inspectors had identified suspect areas and said…
Severance payment deadline for pension-plan safe harbor
A jointly bargained severance fund asked whether it could pay benefits from an earlier job separation after a worker was rehired and later separated again. EBSA said the safe harbor requires payment…
Employer-owned stop-loss policy and health plan assets
An employer group asked whether stop-loss insurance bought to reimburse a sponsor for health benefit costs belonged to the plan. EBSA said the policy was not a plan asset where the employer owned…
Southern Labor Union emergency relief fund reporting
A labor union asked whether its emergency relief fund could avoid ERISA reporting. EBSA said small death remembrances and strike support alone were outside the welfare-plan definition, but payments…
Revised Federal Schedule of Remuneration for UCX Benefit Eligibility
ETA directed state agencies to use the attached 1992 military remuneration schedule for UCX first claims beginning with the first week after April 4, 1992. Earlier first claims remained under the…
Electrical safety work practices at motor control centers
An engineering firm asked about safety practices for workers operating or working near motor control centers. OSHA said equipment had to be approved and installed safely, testing work belonged to…
Approval of temporary construction power equipment
An electrical contractor asked whether planned temporary power equipment met OSHA construction rules. OSHA said conductors and equipment had to be approved, and equipment found safe by a nationally…
Electrical lockout rules and model programs
An electrical workers' union asked OSHA how a sample lockout program related to electrical safety rules. OSHA explained where compliance with its general lockout provisions also met electrical…
Approval of temporary construction electrical equipment
An electrical contractor asked OSHA whether proposed temporary construction power equipment met its rules. OSHA said all electrical conductors and equipment must be approved, and it would accept…
Asbestos exposure sampling during resilient-floor removal
An OSHA scientist reviewed asbestos exposure measurements from resilient-floor removal jobs. The memo said measured exposures were generally below the action level when the studied method was…
Hearing conservation and confined-space welding in tank construction
An OSHA area office reviewed a tank builder's hearing conservation and confined-space practices. It said hearing protection alone did not satisfy the construction noise requirements and requested…
Payment of Interest from a State Unemployment Fund
ETA interpreted federal unemployment law to bar paying interest on late benefit payments or on contribution refunds from a state unemployment fund. A state may refund interest only when that…
Corrections and additional EUC questions and answers
ETA corrected two answers in UIPL 09-92 concerning reachback eligibility and the monetary qualifications of an underlying claim. It also answered additional state questions about former service…
Resheathing devices and OSHA product review policy
A catheter manufacturer asked OSHA to review a safety device's product literature. OSHA said its then-current enforcement instruction allowed appropriate resheathing devices, but resource limits…
Emergency response training for agricultural chemical spills
An agricultural cooperative asked whether its spill-response course qualified workers for operations or technician duties and whether OSHA would approve the course. OSHA said training had to match…
Volunteer firefighters and HAZWOPER in New York
A hospital nurse asked whether OSHA safety rules covered New York volunteer firefighters. OSHA said federal OSHA did not cover state and local government employees, while New York's public-employee…
Worker refusal of HAZWOPER medical surveillance
An employer asked what to do when a worker declined HAZWOPER medical surveillance. OSHA said employers had to make surveillance and consultation available but did not have to compel participation;…
Insulated tools near energized electrical parts
An employer asked whether tools and handling gear used near exposed energized parts had to be insulated, and whether insulated gloves could replace them. OSHA said insulation was needed where the…
Recording repeated hearing shifts on OSHA injury logs
A company asked how to record repeated audiograms showing the same hearing shift. OSHA said the shift should be logged once, when first detected, and the recorded audiogram then became the reference…
Transition to the bloodborne pathogens standard
OSHA told regional staff how to handle complaint inspections while different parts of its bloodborne pathogens standard were taking effect in 1992. It said an earlier enforcement instruction would…
Training for HAZWOPER incident commanders
A safety consultant asked how many training hours a hazardous-material incident commander needed. OSHA said the 24-hour figure was a minimum and that commanders require more than 24 hours of total…
Location of OSHA injury logs for fixed and mobile worksites
A contractor asked where to keep OSHA injury logs for project sites. OSHA said an operation lasting more than a year was generally a fixed establishment and needed an updated log available at the…
Recording clusters of workplace illness symptoms
An OSHA regional office asked about employees reporting similar symptoms at two communications facilities. OSHA said the symptom cases described were work-related illnesses under its then-current…
Food plant exit doors sealed with a bolt
An OSHA regional administrator reported that a food plant had replaced a padlock on an exit door with a bolt and breakable wire seal. The memo said the door still failed OSHA's exit requirements…
EPA and OSHA coverage of public hazardous-material responders
A workers' union asked which agency's hazardous-material response rule protected state and local government employees. OSHA said state plans covered public workers where approved, while EPA's…
Evaluation of the Department of Labor's (DOL) Transition Assistance Program (TAP)
ETA told state unemployment agencies that contractors evaluating the military Transition Assistance Program might request benefit and wage information for sampled former service members. The…
Baseline audiograms for recording occupational hearing loss
A manufacturer asked which baseline audiogram to use when recording hearing loss. OSHA said the hearing-conservation baseline established under its 1983 rule was appropriate, and that a recorded 25…
Emergency Unemployment Compensation Act of 1991 - Questions and Answers
ETA answered state agency questions about eligibility, reachback periods, disqualifications, benefit duration and financing under the 1991 emergency unemployment compensation program. Change 1 later…
Recording occupational hearing shifts on the OSHA 200 Log
An employer questioned OSHA's then-current enforcement policy for occupational hearing loss. OSHA explained its 25 dB shift criterion, said recording smaller 10 dB shifts also complied, and said…
Hearing-loss recording policy and baseline definition
A manufacturer asked about OSHA's hearing-loss recording memoranda and whether the policy required rulemaking. OSHA said the memoranda addressed enforcement of an existing rule, and defined the…
One-time recording of hearing shifts and citation policy
A safety professional asked about OSHA's hearing-loss log policy. OSHA said employers recording 10 dB standard threshold shifts satisfied its then-current enforcement policy, while its minimum…
Washington and federal oil-spill cleanup training rules
A federal OSHA office compared Washington's oil-spill cleanup directive with federal HAZWOPER guidance. It said Washington called for at least eight hours of training for low-risk cleanup workers,…
Protective gloves for workers handling sharp utensils
A member of Congress asked about injuries to a dishwasher handling sharp utensils. OSHA said its general duty and protective-equipment rules could apply even without a standard specific to kitchen…
HAZWOPER coverage for underground storage tank work
A consulting firm asked when underground storage tank work triggered HAZWOPER training and medical surveillance. OSHA said the answer depended on factors such as government-required cleanup,…
Eagle Pass Task Force - Recommended Actions for Deterring and Detecting Fraud Activity in the Unemployment Insurance (UI) Program
After reviewing a multi-state fraud scheme, ETA recommended that state unemployment agencies consider signature checks, searches for many claims at one address, mail-drop checks, and claimant…
Multiple-beam crane lifts during steel erection
An OSHA region asked how to handle a steel erector's plan to lift several beams at once. OSHA discussed manufacturer limits and other lifting rules under its 1991 approach. OSHA later edited the…
Lockout and guarding in cellular manufacturing
A manufacturer asked when tool changes in an automated machining cell needed lockout rather than machine guarding. OSHA said routine, repetitive work integral to production could fall outside…
Hearing conservation duties and injury-log criteria
A senator asked OSHA to clarify how its hearing-conservation rule related to recording hearing loss on injury logs. OSHA said the conservation rule's duties were unchanged, while its recordkeeping…
Lifesaving skiffs and life jackets for work over water
A construction union asked what made a lifesaving skiff immediately available when workers were above water. OSHA listed launch, staffing, communication, equipment, and response factors, and said…
Securing ladders during precast-concrete connections
A precast-concrete company asked how to protect workers connecting columns while on ladders. OSHA said ladder bases on slippery concrete had to be secured and top rails supported equally; it also…
HAZWOPER training across a multi-use cleanup site
A facility asked whether HAZWOPER training applied to every worker across a large site and what happened when a worker missed a refresher. OSHA said training followed actual or potential exposure…
Older manlifts and later design standards
A parking operator asked OSHA to grandfather two manlifts installed in 1956 and 1964. OSHA said the cited design requirement applied to equipment installed after its 1971 effective date, so those…
Proposed accreditation of hazardous-waste training programs
A state emergency-services office asked about proposed accreditation of hazardous-waste training courses. OSHA described the proposal's then-planned scope and said employers, not OSHA, documented…
Employer certification of HAZWOPER training
An engineering company asked who certifies employees who take HAZWOPER training. OSHA said employers could use an in-house program and had to document or certify each worker's qualifying instruction…
Scaffold planks and the four-to-one design factor
A supplier asked OSHA whether a scaffold plank met construction standards. OSHA said it does not approve products, but the planks appeared acceptable if properly installed and loaded. It cautioned…
Insulating barriers for cranes near overhead power lines
A regional administrator asked which insulating barriers could protect equipment working within 10 feet of overhead power lines. OSHA said rubber insulating equipment can protect against brushing…
Knots in fall-protection lanyards and safety lines
A safety engineer asked whether workers may tie knots in fall-protection rope lanyards and lines. OSHA said knots are not prohibited in those lines, though they can reduce breaking strength by up to…
Protective helmets during scaffold erection
A safety advisor asked whether workers erecting a scaffold need helmets when nothing is above them. OSHA said they do: handling scaffold material at head height, moving between scaffold members, and…
Rear clearances for fixed ladders in elevator pits
A consultant asked about space behind fixed vertical ladders in elevator pits. OSHA described the 7-inch rung clearance, a 4.5-inch minimum at unavoidable obstructions, and a separate 4-inch…
Distance from excavation sidewalls as cave-in protection
A consultant asked whether staying away from a vertical excavation wall could protect its employee from cave-ins. On the facts described, OSHA said the employee was not exposed while at least twice…
Emergency-response training for hospital ethylene oxide leaks
A consultant asked what training a hospital maintenance worker needed to respond to ethylene oxide leaks. OSHA said the training depends on the expected response and worst-case release; handling all…
Ground-continuity monitors and construction cord-set testing
A safety specialist asked whether ground-continuity monitors satisfy construction-site cord and receptacle testing requirements. OSHA said a monitor wired to a cord plug does not test that cord,…
OSHA standards for lift-slab bridge construction
A construction company asked which OSHA standards applied to a lift-slab bridge. OSHA said construction standards generally applied, with separate rules for cast-in-place concrete, precast sections,…
Application of Extended Benefits (EB) Work Test to Weeks of Partial and Part-total Unemployment
ETA said that an extended-benefit claimant still attached to a regular employer during a week of partial unemployment may use that continuing contact as evidence of a systematic work search. A…
Leather-shoe policy for truck drivers
A union representative asked whether OSHA had a position on requiring truck drivers to wear leather shoes instead of leather sneakers or deck shoes. OSHA said the described drivers did no manual…
Protective footwear for foundry workers exposed to molten metal
An inquirer asked about protective shoes for foundry workers exposed to molten metal. OSHA said openings in protective equipment that allow exposure to the hazard violate its cited standard, and…
When trenches require air sampling
A contractor association asked whether all trenches deeper than four feet need air sampling. OSHA said the cited rule applies where oxygen deficiency or another hazardous atmosphere exists or could…
Fiberglass labels under the Hazard Communication Standard
OSHA told its regional offices that fibrous-glass products needed warnings about potential carcinogenicity under the Hazard Communication Standard, while warning labels did not need to name a cancer…
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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.