State and Federal Labor Guidance

Free state and federal labor-agency opinion letters, administrative policies, and interpretive notices, with plain-English summaries, current status, and the official source on every page.

8,653 documents and counting · 8 states + federal · Updated October 28, 2026
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US

Process safety coverage for propane filling and delivery Unknown

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…

1992-10-09-1 Opinion Letter October 9, 1992
US

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…

1992-10-09-0 Opinion Letter October 9, 1992
US

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…

1992-10-08 Opinion Letter October 8, 1992
US

Scaffold support system review and product endorsement policy Unknown

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…

1992-10-06-1 Opinion Letter October 6, 1992
US

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…

1992-10-06-0 Opinion Letter October 6, 1992
US

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…

1992-10-06 Opinion Letter October 6, 1992
US

First aid staffing and bloodborne pathogen coverage Unknown

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…

1992-10-05-7 Opinion Letter October 5, 1992
US

First aid proximity, designated aiders, and bloodborne pathogen coverage Unknown

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…

1992-10-05-0 Opinion Letter October 5, 1992
US

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,…

1992-10-05 Opinion Letter October 5, 1992
CA

A hospital's 14-day/80-hour overtime schedule under Wage Order 5-89 must be voluntarily agreed to by the employee, unlike its federal FLSA counterpart

Following up on correspondence to a Senior Deputy Labor Commissioner about Section 3(C) of Wage Order 5-89 (the 14-day, 80-hour overtime work-period option for hospitals), DLSE wrote to clarify it…

1992.10.02 Opinion Letter October 2, 1992
US

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…

1992-10-02-1 Opinion Letter October 2, 1992
US

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…

1992-10-02-0 Opinion Letter October 2, 1992
US

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…

1992-10-02 Opinion Letter October 2, 1992
US

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…

1992-10-01-1 Opinion Letter October 1, 1992
US

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…

1992-10-01 Opinion Letter October 1, 1992
US

FCE health and welfare trust as a MEWA Unknown

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,…

Advisory Opinion 1992-20A Opinion Letter September 30, 1992
US

Richmond police association welfare and pension benefits Unknown

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…

Advisory Opinion 1992-19A Opinion Letter September 30, 1992
US

Simmons short-term disability pay as payroll practice Unknown

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…

Advisory Opinion 1992-18A Opinion Letter September 30, 1992
US

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…

1992-09-30 Opinion Letter September 30, 1992
US

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…

1992-09-28 Opinion Letter September 28, 1992
US

Medical record retention and chemical labels in dental offices Unknown

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…

1992-09-25 Opinion Letter September 25, 1992
US

Recording bloodborne pathogen exposures and worker privacy Unknown

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…

1992-09-24-0 Opinion Letter September 24, 1992
US

Eye foreign-body removal as first aid or medical treatment Unknown

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…

1992-09-24 Opinion Letter September 24, 1992
US

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…

1992-09-22 Opinion Letter September 22, 1992
US

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…

1992-09-21-0 Opinion Letter September 21, 1992
US

JTPA Title III eligibility for former armed forces members Withdrawn

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…

TEGL No. 1-92 Guidance September 18, 1992
US

Steel erection fall protection and construction subparts Unknown

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…

1992-09-18 Opinion Letter September 18, 1992
US

Protective equipment for hospital hazardous substance response Unknown

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…

1992-09-17-3 Opinion Letter September 17, 1992
US

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…

1992-09-17-1 Opinion Letter September 17, 1992
US

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,…

1992-09-17-0 Opinion Letter September 17, 1992
US

Decompression tables for commercial diving Unknown

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…

1992-09-17 Opinion Letter September 17, 1992
US

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…

1992-09-16-0 Opinion Letter September 16, 1992
US

Hearing shifts and self-administered care on injury logs Unknown

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…

1992-09-15-1 Opinion Letter September 15, 1992
US

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…

1992-09-15-0 Opinion Letter September 15, 1992
US

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.…

1992-09-11 Opinion Letter September 11, 1992
US

Medical records and contaminated laundry under the bloodborne rule Unknown

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…

1992-09-10-0 Opinion Letter September 10, 1992
US

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…

1992-09-10 Guidance September 10, 1992
US

Eyewash fountain testing and hot water hazards Unknown

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…

1992-09-09-2 Opinion Letter September 9, 1992
US

Bloodborne pathogens requirements and costs for dental offices Unknown

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…

1992-09-09-1 Opinion Letter September 9, 1992
US

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…

1992-09-09 Opinion Letter September 9, 1992
US

Utility work at hazardous waste sites under HAZWOPER Unknown

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…

1992-09-08-0 Opinion Letter September 8, 1992
US

Recording a blood exposure outside designated first aid work Unknown

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…

1992-09-08 Opinion Letter September 8, 1992
US

Bloodborne pathogen training content for first aid responders Unknown

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…

1992-09-04-2 Opinion Letter September 4, 1992
US

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…

1992-09-04-1 Opinion Letter September 4, 1992
US

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,…

1992-09-04-0 Opinion Letter September 4, 1992
US

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…

1992-09-04 Opinion Letter September 4, 1992
US

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…

1992-09-03 Opinion Letter September 3, 1992
US

Lost workday counts after an injured employee is terminated Unknown

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…

1992-09-02-2 Opinion Letter September 2, 1992
US

Separate injury logs for each residential care home Unknown

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…

1992-09-02-1 Opinion Letter September 2, 1992
US

Recordkeeping tests, aggravation and phobia symptoms Unknown

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…

1992-09-02-0 Opinion Letter September 2, 1992
US

Consolidation of the Attachments to GAL 4-92 Incorporating GAL 4-92, Changes 1 Through 4 Unknown

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…

UIPL No. 47-92 Guidance September 1, 1992
US

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…

1992-09-01-2 Opinion Letter September 1, 1992
US

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…

1992-09-01-1 Opinion Letter September 1, 1992
US

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…

1992-09-01-0 Opinion Letter September 1, 1992
US

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…

1992-09-01 Opinion Letter September 1, 1992
US

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…

1992-08-28-2 Opinion Letter August 28, 1992
US

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…

1992-08-28-0 Opinion Letter August 28, 1992
US

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…

1992-08-28 Opinion Letter August 28, 1992
US

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…

1992-08-27-1 Opinion Letter August 27, 1992
US

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…

1992-08-27-0 Opinion Letter August 27, 1992

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