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

Construction safety rules and public hazards

A member of Congress asked about construction standards, including noise, overhead protection, and work near blind people. OSHA identified the relevant federal topics and said its regulations govern…

1992-05-18-1 Opinion Letter May 18, 1992
US

Gloves for allergy injections and skin testing

A lawyer asked whether clinicians needed gloves for allergy injections and skin tests. OSHA said gloves generally were unnecessary if hand contact with blood or other potentially infectious material…

1992-05-18 Opinion Letter May 18, 1992
US

Material safety data sheets for common workplace cleaners

A physician asked whether a medical office needed material safety data sheets for cleaners also sold to households. OSHA said the consumer-product exception applied when employee use resembled…

1992-05-15 Opinion Letter May 15, 1992
US

Identifying Tax Items on Employer Contribution Reports

ETA told state unemployment agencies to identify only payments into the state unemployment fund as contributions on employer contribution-report lines. Other payroll taxes and surcharges could be…

UIPL No. 25-92 Guidance May 14, 1992
CA

DLSE reverses its 1984 mixed-rate overtime policy and describes a weighted average

Prompted by a challenge to its enforcement position, DLSE reevaluated how to calculate the overtime premium when an employee is paid two or more different hourly rates in one day (for example, a…

1992.05.14 Opinion Letter May 14, 1992
US

How OSHA investigates chemical accidents Unknown

A researcher asked how OSHA investigates chemical accidents. OSHA described the purpose of workplace fatality and multiple-injury investigations and the instructions then used for significant…

1992-05-14 Opinion Letter May 14, 1992
US

Rescinded Chicago regional instruction and Indiana state plan Unknown

Indiana's labor department asked whether Chicago Regional Instruction STD 3-9.1 remained effective and applied to its state plan. OSHA said the instruction had been rescinded in May 1989 and had…

1992-05-13-1 Opinion Letter May 13, 1992
US

HAZWOPER refresher and supervisor training

A training provider asked whether a hazardous waste worker becoming a supervisor needed both refresher and supervisor courses. OSHA generally expected eight hours of each in that year, while…

1992-05-13-0 Opinion Letter May 13, 1992
US

Emergency responders near the Waste Isolation Pilot Plant

OSHA considered safety issues for emergency responders along nuclear-waste routes to the Waste Isolation Pilot Plant in New Mexico. It said HAZWOPER emergency response provisions, or applicable…

1992-05-13 Opinion Letter May 13, 1992
US

Guarding ladderway floor openings Unknown

An employer asked what the former ladderway opening rule required for railings, toeboards, and an entrance barrier. OSHA said exposed sides needed both a standard railing and toeboard, and a…

1992-05-12-1 Opinion Letter May 12, 1992
US

Handling extracted teeth used in dental education

A dental educator asked how extracted teeth should be collected and handled for student training. OSHA treated natural teeth as specimens under the bloodborne pathogens rule unless properly…

1992-05-12-0 Opinion Letter May 12, 1992
US

Bloodborne pathogen coverage at residential care facilities

A residential care facility asked whether hepatitis B testing of residents waived its duty to offer vaccination to staff. OSHA said no; the employer must identify jobs with reasonably anticipated…

1992-05-12 Opinion Letter May 12, 1992
US

Crane-hoisted boatswain chairs in drilled foundations Unknown

A foundation drilling association questioned applying general construction rules to drilled shaft entry and crane-hoisted boatswain chairs. OSHA said those operations posed excavation,…

1992-05-11-0 Opinion Letter May 11, 1992
US

HAZWOPER training during hazardous-site post-closure work

A safety consultant asked what training workers needed for inspection and maintenance at a closed hazardous waste site. OSHA said closure alone did not eliminate possible exposure; employers must…

1992-05-11 Opinion Letter May 11, 1992
US

How HAZWOPER interacts with hazard communication rules Unknown

OSHA clarified how its hazardous waste and emergency response rule interacts with hazard communication and substance-specific health standards. It said hazard communication training covers existing…

1992-05-08 Opinion Letter May 8, 1992
US

Protective clothing for pediatric dental care

A dentist asked whether a regular long-sleeved shirt could replace a clinic jacket when treating children. OSHA said the choice depends on whether the garment prevents blood or other potentially…

1992-05-06 Opinion Letter May 6, 1992
US

Bloodborne pathogen protections for summer camp staff

A camping association asked which short-term camp workers fall under the bloodborne pathogens rule. OSHA said nurses and staff expected to give first aid with reasonably anticipated blood exposure…

1992-05-05-2 Opinion Letter May 5, 1992
US

Aluminum rail design for trench shoring

An equipment company asked how to use aluminum rails in a trench shoring design. OSHA said its example tables did not directly match the proposed vertical rail, so a registered professional engineer…

1992-05-05-1 Opinion Letter May 5, 1992
US

Compressed gas cylinders transported in underground tunnels

A tunnel contractor asked about transporting gas cylinders underground in a position the construction rule generally prohibited. OSHA said it would treat the described project method as a de minimis…

1992-05-05-0 Opinion Letter May 5, 1992
US

HAZWOPER training for hazardous-site observers

A consultant asked what training employees who observe and write reports at hazardous waste sites need. OSHA said the answer depends on their actual exposure risk and duties: covered general site…

1992-05-05 Opinion Letter May 5, 1992
US

Bloodborne pathogen coverage for telecommunications first-aid staff

A telecommunications company asked whether its employees trained in first aid were all covered by the bloodborne pathogens standard. OSHA said coverage turns on whether first aid or medical…

1992-04-28 Opinion Letter April 28, 1992
CA

DLSE reverses its 1984 overtime-premium policy for mixed hourly rates, initially describing a daily weighted-average calculation

Responding to the same attorney correspondence addressed three weeks later in DLSE opinion letter 1992.05.14, DLSE announced it was reversing its 1984 enforcement policy of basing the overtime…

1992.04.27-1 Opinion Letter April 27, 1992
CA

'Floating' birthday/anniversary holidays that can be taken any time are really vacation days, so unused ones must be paid out under Suastez

An employer's counsel asked DLSE to confirm that employees who worked the days before and after their birthday/anniversary "floating holiday" but never took the day off forfeit the benefit, rather…

1992.04.27 Opinion Letter April 27, 1992
US

Scaffold platforms on rough-terrain forklift forks Unknown

OSHA staff asked which construction rules could be cited for work platforms supported by rough-terrain forklift forks. OSHA listed then-current scaffold and general-duty provisions that could apply…

1992-04-27 Opinion Letter April 27, 1992
US

Disinfectants for bloodborne pathogen cleanup Unknown

A lawyer asked OSHA to clarify disinfectants under its bloodborne pathogens enforcement guidance. OSHA said its then-current position called for a tuberculocidal disinfectant for blood or body-fluid…

1992-04-24-3 Opinion Letter April 24, 1992
US

Historical injury-log treatment of later care and work restrictions Unknown

A contractor asked ten questions about recording injuries on the former OSHA Log 200, including later medical care, prescribed work restrictions, disputed claims, teeth, and prosthetic devices. OSHA…

1992-04-24-2 Opinion Letter April 24, 1992
US

Historical retail exemptions from injury logs Unknown

A retailer asked why some retail industries were exempt from keeping routine OSHA injury logs. OSHA described the then-current industry selection method and said exempt employers still had to report…

1992-04-24-1 Opinion Letter April 24, 1992
US

Historical work-relatedness and establishment injury logs Unknown

Maine's labor department asked about uncertain work causation and where to keep injury logs across buildings and mobile work. OSHA explained its then-current work-relatedness presumption and…

1992-04-24-0 Opinion Letter April 24, 1992
US

Historical injury logging for temporary assignments and contractors Unknown

A utility asked which location should log injuries of employees on temporary assignments and outside contractors. Under the then-current recordkeeping system, OSHA said an employee injured at…

1992-04-24 Opinion Letter April 24, 1992
US

Unemployment Compensation for Federal Employees (UCFE)--Coverage Ruling for Employees and Members of Agricultural Promotion Boards and Marketing Agreement and Order Administrative Committees

ETA ruled that employees of agricultural promotion boards and marketing committees perform federal service for unemployment compensation for federal employees, while members of those boards and…

UIPL No. 23-92 Guidance April 21, 1992
US

Average Weekly Benefit Amount (AWBA) for Major Disasters that Occur During the Third Quarter of Fiscal Year (FY) 1992 (April 1 through June 30, 1992) Unknown

ETA directed states to use the attached average weekly benefit amounts when calculating disaster unemployment assistance for major disasters in April through June 1992. It said states should round…

UIPL No. 22-92 Guidance April 21, 1992
US

Eating and drinking near bloodborne pathogen work

A physician asked whether the bloodborne pathogens rule barred food and drink throughout an office. OSHA said eating and drinking were prohibited in areas where blood-related work or contamination…

1992-04-21 Opinion Letter April 21, 1992
US

Adding employee assistance benefits to an ERISA welfare plan Unknown

A painting industry welfare fund asked whether it could add an employee assistance program without changing its ERISA status. EBSA said an entity that already provides listed welfare benefits…

Advisory Opinion 1992-12A Opinion Letter April 20, 1992
US

Hand and torso protection for retail meat cutters

A union asked whether OSHA's meat-cutting protective-equipment directive still applied to retail food operations. OSHA said the directive's substance remained in effect, with suitable hand and torso…

1992-04-17-1 Opinion Letter April 17, 1992
US

Menstrual products and bloodborne pathogen waste

A safety specialist asked whether discarded menstrual products were regulated waste under the bloodborne pathogens rule. OSHA said they generally were not because absorbent material ordinarily…

1992-04-17-0 Opinion Letter April 17, 1992
US

Janitorial workers and the bloodborne pathogens rule

A lawyer asked whether janitorial workers at non-health-care workplaces fell under the bloodborne pathogens rule. OSHA said those workers generally were not assumed to have occupational exposure,…

1992-04-17 Opinion Letter April 17, 1992
US

Employer training for rear-fly extension ladders

A requester raised concerns about instructions for a rear-fly extension ladder. OSHA said the ladder itself met the cited requirements, but an employer providing it to employees had to use a…

1992-04-16-0 Opinion Letter April 16, 1992
US

Interactive bloodborne pathogen training by telephone

A hospital asked whether bloodborne pathogen training could meet the interactive question-and-answer requirement without a trainer in the room. OSHA said a generic or computer program needed…

1992-04-16 Opinion Letter April 16, 1992
US

Replacement parts and crane capacity under former rules Unknown

A crane company asked when replacement parts required a manufacturer's approval. Under the rule it cited, OSHA said equivalent parts that did not affect capacity or safe operation could be used…

1992-04-15-5 Opinion Letter April 15, 1992
US

Private inspectors of construction cranes under former rules Unknown

A company asked how a private inspector could become recognized to perform annual construction-crane inspections. OSHA said that, although the then-current rule mentioned recognition, it had no…

1992-04-15-4 Opinion Letter April 15, 1992
US

Plywood sheeting in trench shoring systems

A plywood association asked how excavation shoring tables applied to plywood. OSHA said the cited appendix note allowed plywood to contain raveled soil and transfer its loads, but not to replace…

1992-04-15-3 Opinion Letter April 15, 1992
US

Extension cords during construction work

An electrical contractor asked whether extension cords connected to permanent wiring were temporary wiring during construction. OSHA said the work being performed determines whether construction…

1992-04-15-1 Opinion Letter April 15, 1992
US

Gloves when handling closed serum specimen containers

A laboratory asked whether staff needed gloves to handle unopened serum containers. OSHA said gloves were appropriate because contamination could be invisible, though the standard did not…

1992-04-15-0 Opinion Letter April 15, 1992
US

Competent and interactive bloodborne pathogen training

An attorney asked what qualifies someone to teach bloodborne pathogen training and whether video alone suffices. OSHA said employers must assess a trainer's competence and knowledge of the…

1992-04-15 Opinion Letter April 15, 1992
US

Handwashing facilities and antiseptic alternatives

A company asked whether a hand-disinfecting system met bloodborne pathogen handwashing rules. OSHA said readily accessible soap-and-water facilities and prompt handwashing after glove removal were…

1992-04-09 Opinion Letter April 9, 1992
US

Sky-Web interior fall protection system review Unknown

A construction company asked OSHA for further comment on its interior fall protection system. OSHA said it does not approve products because jobsite conditions and use matter. Based on the company's…

1992-04-08-1 Opinion Letter April 8, 1992
US

Washing machine types for contaminated protective clothing

A fire department asked whether laundering protective clothing required front-loading rather than top-loading washing machines. OSHA said the federal bloodborne pathogens rule made no distinction…

1992-04-08 Opinion Letter April 8, 1992
US

Emergency responder roles and training under HAZWOPER

OSHA reviewed an EPA fact sheet on emergency responder agreements and explained how HAZWOPER applies to community response. Employers planning to send workers into emergencies need a response plan…

1992-04-07 Opinion Letter April 7, 1992
US

Bloodborne pathogen coverage for telecom first-aid providers

A telecommunications company asked whether its first-aid-trained workers fell under the bloodborne pathogens rule. OSHA said designated employees expected to render first aid were covered, while…

1992-04-06 Opinion Letter April 6, 1992
US

Nail and tissue clippers as contaminated sharps

A podiatrist asked whether clippings and clippers were covered by bloodborne pathogen rules. OSHA said toenail clippings and skin shavings were covered if contaminated with blood or similar…

1992-04-04 Opinion Letter April 4, 1992
US

Bloodborne pathogen coverage for laundromat workers Unknown

A member of Congress asked whether a public laundromat and dry cleaner fell under the bloodborne pathogens rule. OSHA said workers in health-care or institutional laundry could have occupational…

1992-04-02-1 Opinion Letter April 2, 1992
US

Carrying objects while climbing construction ladders

A roofing contractor sought a variance to let employees carry materials on ladders. OSHA said the cited rule already allowed carrying an object if doing so did not cause loss of balance or control,…

1992-04-02-0 Opinion Letter April 2, 1992
US

HAZWOPER duties for hazardous-waste truck drivers

A hazardous-waste truck driver asked what training applied to his work. OSHA said HAZWOPER covered drivers assigned to respond to hazardous-substance emergencies or enter hazardous-waste sites; the…

1992-04-02 Opinion Letter April 2, 1992
US

Unit voting by jointly managed benefit plan trustees Unknown

Greyhound benefit trusts asked whether their union and employer trustees could vote as separate blocs. EBSA said sections 403(a) and 404(a)(1) of ERISA did not prohibit that decision method merely…

Advisory Opinion 1992-11A Opinion Letter March 31, 1992
US

Historical injury logging during a commute home Unknown

A company asked whether an injury after a worker left its parking lot on the normal commute home belonged on the former OSHA Log 200. OSHA said the normal commute was not work related under its…

1992-03-31-1 Opinion Letter March 31, 1992
US

HAZWOPER training for hospital decontamination staff

A hospital asked what training nurses and other staff needed when receiving contaminated hazardous-waste-site patients. OSHA said roles determine training: designated hospital staff operating…

1992-03-31-0 Opinion Letter March 31, 1992
US

Assigned first-aid staff under the bloodborne pathogens rule

A consultant asked about first-aid employees assigned in manufacturing and construction workplaces. OSHA said workers trained in first aid and designated to provide medical assistance as a job duty…

1992-03-31 Opinion Letter March 31, 1992
US

Procedures for release of 1991 unemployment insurance quality-control data Withdrawn

ETA told state unemployment agencies to freeze their 1991 benefits quality-control data on April 24, reconcile draft annual reports, and release their results by June 26, 1992. The letter and…

UIPL No. 21-92 Guidance March 30, 1992
US

Site characterization and HAZWOPER training at a cleanup site

An OSHA regional office asked whether HAZWOPER applied at a Superfund cleanup site based on soil samples and exposure modeling. OSHA said employers must characterize the site continuously and…

1992-03-30 Opinion Letter March 30, 1992
US

Towing crews as skilled support at hazardous-material emergencies

Arizona public-safety staff asked how towing employees fit into HAZWOPER emergency response. OSHA said a crew called temporarily for equipment skills could receive an incident briefing as skilled…

1992-03-27 Opinion Letter March 27, 1992

How this guidance is useful

  • See how the agency reads the law: An opinion letter shows how a state labor agency actually applied wage-and-hour law to a real employer's or worker's situation.
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