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

HAZWOPER coverage and training for utility work at waste sites

A utility asked when maintenance, soil work, inspections, and meter reading at hazardous-waste sites trigger HAZWOPER. OSHA said the answer depends on site characterization and actual or reasonably…

1991-11-19 Opinion Letter November 19, 1991
US

Historical OSHA 200 hearing-loss recording policy Unknown

A hearing-conservation company asked about OSHA’s then-current OSHA 200 log policy. OSHA said a work-related 25 dB average shift from the original baseline at specified frequencies was recordable,…

1991-11-15 Opinion Letter November 15, 1991
US

Historical OSHA 200 log criteria for hearing shifts Unknown

An audiometric testing company asked whether a 10 dB standard threshold shift had to go on the OSHA 200 log. OSHA said its then-current federal enforcement criterion for a work-related log entry was…

1991-11-14 Opinion Letter November 14, 1991
US

UCX - Separation Pay for Regular Enlisted Ex-Servicemembers Unknown

ETA instructed state agencies to apply their own unemployment laws to separation pay received by former regular enlisted service members who claim UCX benefits. Staff should check the DD Form 214…

UIPL No. 05-92 Guidance November 13, 1991
US

Emergency versus incidental hazardous-substance releases

A consultant asked when a hazardous-substance release counts as an emergency under HAZWOPER. OSHA said there is no fixed quantity threshold; likely severe exposure, oxygen deficiency, fire or…

1991-11-08 Opinion Letter November 8, 1991
US

Design and use of trench shields and manhole boxes

A manufacturer asked about driven trench shields, round pipe manhole boxes, and stacked shields. OSHA said the designs could be used if a registered professional engineer approved them and they were…

1991-11-07-1 Opinion Letter November 7, 1991
US

Supervised field experience for HAZWOPER trainees

An inquirer asked what counts as three days of actual field experience for a HAZWOPER trainee. OSHA said this supervised work follows classroom instruction and lets the new worker become familiar…

1991-11-07 Opinion Letter November 7, 1991
US

Posting mobile-crane load charts in the cab Unknown

A regional administrator asked how mobile-crane load charts could meet posting and visibility rules. OSHA said a notebook securely attached inside the cab could satisfy the posting requirement if…

1991-11-05-2 Opinion Letter November 5, 1991
US

Tractor rollover structures meeting later consensus standards

A tractor maker asked whether rollover protective structures meeting newer SAE and ASAE standards could satisfy OSHA’s agricultural tractor requirements. OSHA said structures meeting ANSI/SAE J2194…

1991-11-05-1 Opinion Letter November 5, 1991
US

Grounding and bonding of portable generators

A generator maker asked whether bonding a portable generator’s neutral to its frame was optional when it supplies a separately derived system. OSHA said it was required, and explained when the frame…

1991-11-05-0 Opinion Letter November 5, 1991
US

Whether permanent handrails must be painted yellow

A protective-coating specialist asked whether OSHA’s yellow caution-color rule required every permanent handrail to be painted yellow. OSHA said the rule was not meant to impose that requirement.

1991-11-05 Opinion Letter November 5, 1991
CA

Wage Order 5-89 has no overtime exemption for 48-hour weekend shifts; a weekend lump sum does not set an hourly rate

A retirement facility's counsel asked what overtime rules apply to two weekend-only workers who would be "on duty" from Friday afternoon to Sunday afternoon, a total of 48 hours, and whether they…

1991.11.01-4 Opinion Letter November 1, 1991
CA

Truck drivers who split their day between CHP-regulated and unregulated duties: only the unregulated hours count toward daily/weekly overtime

Employer counsel wrote to confirm DLSE's enforcement policy on overtime for truck drivers who spend part of the day performing duties regulated by the California Highway Patrol under Title 13 of the…

1991.11.01-3 Opinion Letter November 1, 1991
US

Bearing monitoring in grain bucket elevators

A grain equipment company asked when a bearing is external to an inside bucket elevator and whether smaller grain facilities need monitoring. OSHA said monitoring generally applies unless the…

1991-10-31 Opinion Letter October 31, 1991
US

Backup alarms on construction vehicles

A senator asked about noise from backup alarms at construction sites. OSHA said a vehicle with an obstructed rear view must have a distinguishable alarm or a worker signaling the driver that backing…

1991-10-29-0 Opinion Letter October 29, 1991
US

Depth ratings for stacked trench shields

A contractor association asked whether every shield stacked in a trench must be rated for the trench’s full depth. OSHA said each shield needs a rating for the depth where it is used, and the stack…

1991-10-29 Opinion Letter October 29, 1991
US

Later consensus standards for agricultural tractor rollover protection

A tractor manufacturer asked whether newer SAE and ASAE rollover protective structures met OSHA’s agricultural tractor requirements. OSHA said structures meeting ANSI/SAE J2194 or ASAE S519 gave…

1991-10-25 Opinion Letter October 25, 1991
US

Average weekly benefit amounts for first-quarter FY 1992 disasters Unknown

ETA supplied state average weekly benefit amounts for calculating disaster unemployment assistance for major disasters from October through December 1991. State agencies were asked to give the…

UIPL No. 01-92 Guidance October 23, 1991
US

Employer self-audits and OSHA enforcement

A company asked whether OSHA might use its own safety audit against it. OSHA encouraged self-audits but said serious hazards left uncorrected could lead to enforcement, and urged the company to…

1991-10-22 Opinion Letter October 22, 1991
US

Historical enforcement of the lockout/tagout standard Unknown

OSHA instructed its regional administrators to keep enforcing the lockout/tagout standard while a court challenge was pending in 1991. It said enforcement would continue unless the court changed the…

1991-10-21 Opinion Letter October 21, 1991
US

Timing and content of HAZWOPER refresher training Unknown

An environmental services company asked whether annual HAZWOPER refreshers must occur on the exact training anniversary and whether shorter job briefings can add up to eight hours. OSHA said…

1991-10-16-1 Opinion Letter October 16, 1991
US

Industry ergonomic guidelines and OSHA citations

A bakers association asked whether its voluntary ergonomics guidance could expose members to OSHA citations. OSHA said it would not target workplaces simply because the industry published guidance…

1991-10-16 Opinion Letter October 16, 1991
US

HAZWOPER response training for home heating oil distributors

A consultant asked what emergency-response training home heating oil distributor employees needed. OSHA said first responder operations training might allow defensive action without stopping the…

1991-10-11 Opinion Letter October 11, 1991
US

HAZWOPER duties of hazardous-materials truck drivers

A trucking association asked when drivers must be trained under HAZWOPER after a hazardous-materials release. OSHA said operators who only evacuate under a suitable plan may need no further response…

1991-10-08 Opinion Letter October 8, 1991
CA

Time worked beyond an adopted alternative-workweek schedule, even below the 10/12-hour straight-time cap, requires premium overtime pay

An employer wrote to DLSE describing conflicting guidance from two district offices about premium pay under an alternative workweek schedule of two ten-hour days and two four-hour days. DLSE…

1991.10.07 Opinion Letter October 7, 1991
US

Locking hooks under the construction crane rule Unknown

A manufacturer asked OSHA for compliance determinations on three locking hooks. OSHA said it does not approve products in advance, because field conditions and use affect safety. Based on the…

1991-10-04 Opinion Letter October 4, 1991
US

Historical manhole-step width enforcement guidance Unknown

OSHA told its regions in 1991 how to handle manhole-step width while a proposed walking-surfaces rule was pending. It said citations should not issue for clear widths as short as 10 inches in the…

1991-10-03 Opinion Letter October 3, 1991
US

Lower-cost HAZWOPER emergency-response training options Unknown

A member of Congress asked about the cost of HAZWOPER emergency-response training for a small employer. OSHA said employers could plan to evacuate under an emergency action plan or train responders…

1991-10-02-0 Opinion Letter October 2, 1991
US

HAZWOPER response levels for firefighters

An inquirer asked what firefighters at different HAZWOPER training levels could do during a hazardous-materials incident. OSHA said awareness-level workers can identify and report a release, while…

1991-10-02 Opinion Letter October 2, 1991
US

Machine setup, lockout, and electrical approval requirements Unknown

An attorney asked which safety and ergonomic rules applied while setting up a two-spindle reaming machine. OSHA said it had no machine-specific ergonomics standard at the time, but identified…

1991-10-01-7 Opinion Letter October 1, 1991
US

Stairway and ladder rule for scaffold access ladders Unknown

A scaffolding institute asked whether construction stairway and ladder rules applied to ladders used for scaffold access. OSHA said the cited subpart did not cover ladders specifically made for…

1991-10-01-6 Opinion Letter October 1, 1991
US

Historical OSHA position on construction stilts Unknown

A manufacturer asked about OSHA rules for construction stilts. OSHA said it had no specific stilt rule at the time and had raised the subject in a pending rulemaking. OSHA labels this historical…

1991-10-01-5 Opinion Letter October 1, 1991
US

Engineered manufacturer tables for trench protection

A trench protection manufacturer asked whether its tabulated data could go beyond the excavation standard’s appendix tables. OSHA said it could if a registered professional engineer approved its…

1991-10-01-4 Opinion Letter October 1, 1991
US

Engineer approval for an added soil classification

A manufacturer asked whether its C-60 soil class could be used for excavation protective-system design. OSHA said manufacturer tables may use classifications outside OSHA’s tables when a registered…

1991-10-01-3 Opinion Letter October 1, 1991
US

Construction vehicle rules for end dump trucks

A consultant asked whether end dump trucks traveling between jobsites must comply with construction vehicle rules once they enter an off-highway site. OSHA said they do, while conflicting Department…

1991-10-01-2 Opinion Letter October 1, 1991
US

Electrical approval and bonding of portable generators

A generator maker asked whether jobsite generators need a laboratory listing and how their neutral and frame must be connected. OSHA said equipment must be approved but a listing is not the only way…

1991-10-01-1 Opinion Letter October 1, 1991
US

Railings on elevated construction stairway landings

A regional administrator asked when construction stairway platforms and landings need railings. OSHA said railings are required on unprotected sides and edges of stairways at least 30 inches high,…

1991-10-01-0 Opinion Letter October 1, 1991
US

Greater-hazard claim for crane anti-two-block devices Unknown

A contractor asked OSHA to suspend an anti-two-block requirement after failures of one device design. OSHA said it could not recognize a greater-hazard defense on the information provided because…

1991-09-30 Opinion Letter September 30, 1991
US

Hazard labels for crystalline silica in finished products

A product maker asked when finished goods containing crystalline silica need hazard labels and material safety data sheets. OSHA said the issue is whether normal use can release more than very small…

1991-09-25-0 Opinion Letter September 25, 1991
US

OSHA and MSHA jurisdiction at a fertilizer facility

A union asked which agency enforced worker safety rules at a fertilizer company’s Port Sutton facility. OSHA said MSHA had exercised jurisdiction there, so OSHA’s standards were preempted at that…

1991-09-25 Opinion Letter September 25, 1991
US

Uniform employer experience measurement

ETA interpreted FUTA’s requirement to measure employers’ unemployment experience over the same period using uniform methods. ETA still lists the letter as continuing.

UIPL No. 29-83, Change 1 Guidance September 24, 1991
US

Historical OSHA informal-conference penalty guidance Unknown

OSHA instructed regional and area offices in 1991 on penalty reductions, grouping related violations, and staffing informal conferences. The memo generally called for regional approval when a…

1991-09-24 Opinion Letter September 24, 1991
US

Hazard communication for volatile amines from humidifiers

An inquirer asked whether hazard-communication duties covered employees exposed to trace amines emitted by steam humidification systems. OSHA said workers who directly handle or store the chemicals…

1991-09-23 Opinion Letter September 23, 1991
US

Crane swing-radius barricade variance request Unknown

A contractor asked to substitute warning lights and an alarm for a physical barricade around a crane’s swing radius. OSHA denied the variance, explaining that the cited rule called for a barrier to…

1991-09-20-0 Opinion Letter September 20, 1991
US

Propane and gasoline response duties under HAZWOPER

An employer asked whether operations-level responders with additional fire training could close a valve inside the danger area during a propane fire. OSHA said this was a narrow special case for…

1991-09-20 Opinion Letter September 20, 1991
US

Date of disaster for disaster unemployment benefit calculations Unknown

ETA interpreted date of the disaster for weekly disaster unemployment assistance calculations as the date a major disaster began or, if later, the date the individual became unemployed. This lets…

UIPL No. 43-91 Guidance September 19, 1991
US

Historical OSHA 200 recording of cumulative trauma disorders Unknown

OSHA told an area office that under its then-current OSHA 200 guidance, a work-related cumulative trauma disorder could be recordable without a physician’s diagnosis if its symptoms met the…

1991-09-17-0 Opinion Letter September 17, 1991
US

Historical recurrence rule for cumulative trauma cases Unknown

A meatpacking company asked when a cumulative trauma disorder case was resolved for OSHA 200 recordkeeping. OSHA said complete resolution of signs and symptoms for 30 days ended the case; recurrence…

1991-09-17 Opinion Letter September 17, 1991
US

Machine guarding in food processing facilities

OSHA answered whether food processors must guard unguarded machinery and power transmission equipment. It said the cited standards provide no food-industry exemption and that contamination concerns…

1991-09-12-1 Opinion Letter September 12, 1991
US

Meatpacking ergonomics guidance and preemployment exams

A meatpacker asked whether OSHA’s ergonomics guidelines conflicted with rules on preemployment medical exams. OSHA said its guidelines did not address preemployment screening; their baseline health…

1991-09-12 Opinion Letter September 12, 1991
US

Fall protection while climbing power transmission towers Unknown

A senator asked whether OSHA had newly extended fall protection to workers climbing power transmission towers. OSHA said its longstanding interpretation covered climbing as well as work stations…

1991-09-10 Opinion Letter September 10, 1991
US

Hazard data sheets for research pharmaceuticals

A research institute asked whether its custom synthesis and distribution of drugs and controlled substances required material safety data sheets. OSHA said the hazard communication rule covered…

1991-09-09-0 Opinion Letter September 9, 1991
US

Hazard warnings for continuous glass filaments Unknown

A lawyer asked whether continuous glass filaments needed cancer warning labels. OSHA said a manufacturer must assess the scientific evidence for its own product and report supported hazards on…

1991-09-06-0 Opinion Letter September 6, 1991
US

OSHA coverage of wholly volunteer ambulance organizations

A volunteer ambulance corps asked whether OSHA required it to offer members hepatitis B vaccination at no charge. OSHA said its jurisdiction covered employers and employees, so an organization whose…

1991-09-06 Opinion Letter September 6, 1991
US

Historical OSHA 200 hearing-loss retest timing Unknown

An employer asked how to log hearing loss and whether a later audiogram could replace the initial result. OSHA said its then-current OSHA 200 entry date was the test date and a retest within 30…

1991-09-04-0 Opinion Letter September 4, 1991
US

Who may remove a lockout device Unknown

OSHA noted that a trade magazine described a foreman removing a worker’s lock during lockout. OSHA said the employee who applied the lock normally must remove it; management can do so only when that…

1991-09-04 Opinion Letter September 4, 1991
CA

Owner-operator truck driver pay plans must separately reimburse vehicle operating costs under Labor Code §2804, and extra commute time beyond a customer delivery must be paid

A trucking company's counsel described a proposed pay plan for employee-drivers who own their own trucks, paying an hourly wage plus a share of the broker's revenue, and asked whether commute time…

1991.08.30 Opinion Letter August 30, 1991
US

Electrical tie wraps in a circuit breaker lockout device Unknown

A manufacturer asked whether its circuit breaker lockout devices complied with OSHA's lockout rule. OSHA said the standard electrical tie wrap in one device was not substantial enough to meet the…

1991-08-30-2 Opinion Letter August 30, 1991
US

Historical prescription-drop injury recordkeeping Unknown

A training company asked whether an eye injury treated with two single doses of prescription drops counted as medical treatment under then-current OSHA recordkeeping guidance. OSHA said it did…

1991-08-30-1 Opinion Letter August 30, 1991
US

Which year to log a delayed audiogram report Unknown

A steel company asked which year’s OSHA 200 log should show a December audiogram whose report arrived in January. OSHA said a recordable case belonged on the log for the year the test was performed,…

1991-08-30-0 Opinion Letter August 30, 1991

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