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

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…

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

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…

1992-08-25-0 Opinion Letter August 25, 1992
US

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,…

1992-08-25 Opinion Letter August 25, 1992
US

Annulment order and pension alternate payee status Unknown

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…

Advisory Opinion 1992-17A Opinion Letter August 21, 1992
US

Atmospheric tank storage under the process safety rule Unknown

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…

1992-08-21-2 Opinion Letter August 21, 1992
US

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…

1992-08-21-1 Opinion Letter August 21, 1992
US

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…

1992-08-21-0 Opinion Letter August 21, 1992
US

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…

1992-08-21 Opinion Letter August 21, 1992
US

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…

UIPL No. 45-92 Guidance August 20, 1992
US

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…

1992-08-19-0 Guidance August 19, 1992
US

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;…

1992-08-19 Opinion Letter August 19, 1992
US

Designated first aid duties under the bloodborne pathogen rule Unknown

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…

1992-08-18-2 Opinion Letter August 18, 1992
US

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…

1992-08-18-1 Opinion Letter August 18, 1992
US

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…

1992-08-18-0 Opinion Letter August 18, 1992
US

EUC questions after the Unemployment Compensation Amendments of 1992 Unknown

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…

UIPL No. 09-92, Change 4 Guidance August 17, 1992
US

Bloodborne pathogen rule excludes construction work in 1992 Unknown

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…

1992-08-14-1 Opinion Letter August 14, 1992
US

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…

1992-08-14-0 Opinion Letter August 14, 1992
US

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…

1992-08-14 Opinion Letter August 14, 1992
US

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…

1992-08-12-2 Opinion Letter August 12, 1992
US

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.…

1992-08-12-1 Opinion Letter August 12, 1992
US

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…

1992-08-12-0 Opinion Letter August 12, 1992
US

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…

1992-08-12 Opinion Letter August 12, 1992
US

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…

1992-08-10 Opinion Letter August 10, 1992
US

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…

1992-08-07-1 Opinion Letter August 7, 1992
US

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…

1992-08-07-0 Opinion Letter August 7, 1992
US

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…

1992-08-07 Opinion Letter August 7, 1992
US

Competent person presence at excavation sites Unknown

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…

1992-08-05-0 Opinion Letter August 5, 1992
US

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…

1992-08-04 Opinion Letter August 4, 1992
US

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) Unknown

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…

UIPL No. 43-92 Guidance July 31, 1992
US

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.…

1992-07-31 Opinion Letter July 31, 1992
US

OSHA inspection, abatement and penalty procedures Unknown

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…

1992-07-30 Opinion Letter July 30, 1992
US

Bleach dilution for bloodborne pathogen decontamination Unknown

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…

1992-07-28-3 Opinion Letter July 28, 1992
US

Formaldehyde concentration under process safety management Unknown

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…

1992-07-28-2 Opinion Letter July 28, 1992
US

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…

1992-07-28-1 Opinion Letter July 28, 1992
US

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,…

1992-07-28-0 Opinion Letter July 28, 1992
US

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…

1992-07-28 Opinion Letter July 28, 1992
US

New Jersey tooling association health plan as a MEWA Unknown

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…

Advisory Opinion 1992-16A Opinion Letter July 27, 1992
US

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…

1992-07-27 Opinion Letter July 27, 1992
US

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…

1992-07-24-1 Opinion Letter July 24, 1992
US

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…

1992-07-24-0 Opinion Letter July 24, 1992
US

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…

1992-07-24 Opinion Letter July 24, 1992
US

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…

1992-07-22-1 Opinion Letter July 22, 1992
US

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…

1992-07-22-0 Opinion Letter July 22, 1992
US

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…

1992-07-22 Opinion Letter July 22, 1992
US

Backhoe work near overhead power lines Unknown

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…

1992-07-21-3 Opinion Letter July 21, 1992
US

Hepatitis B vaccination policy for collateral duty first aiders Unknown

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,…

1992-07-21-2 Opinion Letter July 21, 1992
US

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…

1992-07-21-1 Opinion Letter July 21, 1992
US

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…

1992-07-21-0 Opinion Letter July 21, 1992
US

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…

1992-07-21 Opinion Letter July 21, 1992
US

Construction first aid, scaffolds, lifts and roof access Unknown

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…

1992-07-20-6 Opinion Letter July 20, 1992
US

Emergency eyewash and showers at construction sites Unknown

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,…

1992-07-20-5 Opinion Letter July 20, 1992
US

Recording bloodborne pathogen exposure incidents Unknown

A nurse asked when workplace exposures to hepatitis B or HIV were recordable on the former OSHA 200 log. OSHA said exposure incidents were evaluated as injuries and recorded if they led to listed…

1992-07-20-4 Opinion Letter July 20, 1992
US

Cumulative trauma and injury recordkeeping examples Unknown

An employer asked how to record cumulative trauma disorders and several other work related conditions under OSHA's former recordkeeping system. OSHA gave examples involving positive EMG results,…

1992-07-20-3 Opinion Letter July 20, 1992
US

Workplace vermin control and OSHA jurisdiction

A requester asked whether OSHA regulates vermin at work and whether public and private workplaces face the same rules. OSHA pointed to sanitation standards for permanent workplaces and temporary…

1992-07-20-2 Opinion Letter July 20, 1992
US

Ladder access and fall protection for steel erectors

A construction company asked whether steel erectors needed ladders at every elevation change. OSHA said Subpart X applied to steel erectors, but required a safe ladder or stairway between levels in…

1992-07-20-0 Opinion Letter July 20, 1992
US

Bloodborne pathogens in maintenance and construction work

A mechanical contractors group asked how OSHA's bloodborne pathogens standard applied to maintenance work at health care facilities. OSHA said routine maintenance workers with reasonably anticipated…

1992-07-15 Opinion Letter July 15, 1992
US

Extreme temperature protections for landscaping employees

A requester asked which OSHA standards applied to landscaping workers in extreme temperatures. OSHA identified general industry personal protective equipment and sanitation provisions and described…

1992-07-14-0 Opinion Letter July 14, 1992
US

HAZWOPER coverage of lead contaminated soil cleanup

A lead recycling company asked whether low level lead soil cleanup fell outside HAZWOPER. OSHA said the corrective action was within its scope and that the more protective provision controlled where…

1992-07-14 Opinion Letter July 14, 1992
US

Optional numeric and color coded chemical hazard labels

A dentist asked OSHA to require numeric or color hazard ratings on safety data sheets and containers. OSHA said the hazard communication rule allowed various label formats if required information…

1992-07-10 Opinion Letter July 10, 1992
US

Bloodborne pathogens duties for physicians and hospitals

A physician asked who must provide bloodborne pathogens protections when a professional corporation's doctors practice at a hospital. OSHA said the corporation was generally the physicians' employer…

1992-07-07-1 Opinion Letter July 7, 1992

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