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.
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HAZWOPER and emergency response involving radioactive materials
A state health physicist asked whether HAZWOPER covers emergency response involving radioactive waste. OSHA said the Nuclear Regulatory Commission governs licensed radioactive material inside…
Equivalent HAZWOPER training and site experience
An engineering firm asked whether experienced hazardous-waste workers could be certified as equivalently trained and receive in-house training certificates. OSHA said employers may use documented…
Hazard communication for hospital drugs and medications
A federal hospital agency asked when OSHA's Hazard Communication Standard covers employees preparing or administering medications. OSHA said tablets intended to be crushed before administration are…
TRA and disaster claims filed for incapacitated or deceased workers Unknown
ETA changed its earlier interpretation and allowed an authorized legal representative to file trade readjustment allowance or disaster unemployment assistance claims for an incapacitated or deceased…
Recapping used needles and sharps disposal Unknown
A clinic asked whether needles could be recapped when changing needles after drawing medication. OSHA said used needles generally should go into sharps containers without recapping, but if recapping…
General contractor responsibility for hazard communication
An OSHA regional office asked when a general contractor may be cited for hazard communication violations at a construction site. OSHA said its multi-employer citation approach for hazard…
HAZWOPER and hazard communication training at waste generators
A worker asked what training a hazardous-materials generator must provide to employees who use, package, and move materials to a short-term storage area. OSHA said HAZWOPER depends on the operation,…
Hospital duties under HAZWOPER Unknown
An insurer asked how HAZWOPER applies to hospitals using outside fire departments. OSHA said hospitals are not categorically exempt: an internal hazardous-substance emergency, a hospital role in…
DOT vehicle-rule changes and an OSHA enforcement directive Unknown
An OSHA regional office asked to revise an enforcement directive after changes to federal motor-carrier rules. OSHA said the new DOT definition of a commercial motor vehicle would guide enforcement,…
HAZWOPER training for hazardous waste truck drivers
A trucking company asked whether drivers who transport hazardous waste but do not otherwise handle it need HAZWOPER training. OSHA said workers without exposure or potential exposure to hazards of…
Equivalent and site-specific hazardous-waste training for DOE workers
The Department of Energy asked OSHA to review draft guidance for hazardous-waste worker training. OSHA said equivalent training must still let employees safely perform their duties, including…
Type C soil assumption instead of trench soil testing
A lawyer asked whether an employer must test trench soil if it assumes the weakest Type C category and protects workers accordingly. OSHA said testing would be unnecessary if the employer meets all…
Correction of TCE flammability statement in earlier HAZWOPER letter
OSHA corrected its earlier statement that trichloroethylene had no fire hazard. It said TCE can burn and gave its explosive limits and flash point, but the earlier answer still held for the example…
HAZWOPER coverage for boilermakers in a clean Superfund site area
A contractor asked whether boilermakers rebuilding an incinerator in a clean area of a Superfund site needed HAZWOPER coverage. OSHA agreed the rule would not apply if there was no actual or…
Recording hearing loss and cumulative trauma on the OSHA 200 log Unknown
OSHA issued field guidance on when to record occupational hearing loss and upper-extremity cumulative trauma disorders on the OSHA 200 log. It set a hearing-shift threshold for citations and…
Site-specific HAZWOPER training for industrial emergency teams
A safety consultant asked whether generic HAZWOPER classes suffice for industrial emergency response teams. OSHA said general instruction can cover some topics, but training must also reflect each…
Unpaid 30-minute meal periods are lawful if the employee gets a genuine duty-free opportunity to take them, but employers must pay for reported or known meal-period work
A company employing unsupervised field service technicians asked DLSE whether its practice of an unpaid 30-minute daily lunch period was lawful. DLSE explained that the IWC Orders require a…
Grain elevator inspection program and OSHA fees
A senator asked about increased grain elevator inspections and alleged OSHA user fees. OSHA described a regional inspection emphasis program after full enforcement of the grain-handling standard…
Hazard communication for janitorial contractors
A janitorial company asked how the Hazard Communication Standard applies to mobile workforces and customers' chemicals. OSHA said exposed workers need usable hazard information and training, which…
HAZWOPER training for utility crews stopping leaks Unknown
A utility asked whether crews plugging a leaking transformer and searching for a gas leak were merely skilled support workers. OSHA said the emergency response plan must define roles and training…
Lockout and ignition-key control during truck maintenance Unknown
A laboratory asked whether a worker may adjust a truck from underneath while its engine is running. OSHA said that would present a hazard and violate the lockout and tagout rule. It said shutting…
An employer cannot recover overpaid vacation wages from an employee's final paycheck; that self-help deduction violates the state's wage-exemption public policy
Out-of-state counsel asked DLSE to confirm several statements in a proposed vacation policy, including that an employer could recover overpaid vacation wages from an employee's final paycheck. DLSE…
Chain lanyards and safety nets for construction fall protection Unknown
A civil engineer asked whether chain could serve as a lanyard and whether general contractors must install safety nets. OSHA said its cited rule did not categorically prohibit chain, but discouraged…
Hazard warning labels on outer shipping containers
An OSHA regional office questioned whether outer packages containing hazardous chemical containers need separate Hazard Communication Standard warnings. OSHA reaffirmed that the standard's label…
Equivalent training and refreshers for TSD facility safety staff
An employer asked whether its safety professionals' previous training could count for occasional work at a permitted treatment, storage, and disposal facility. OSHA said equivalent experience may…
OSHA coverage of private workers in a state building
A state senator asked about workers in a termite-damaged state courthouse building. OSHA said federal law did not give it jurisdiction over the state employees there, but private-sector employees…
Certification and refresher training for HAZWOPER responders
An oil company asked how to train and certify its hazardous-materials responders. OSHA said its plan must cover an on-scene incident commander, annual refreshers, and hands-on training; qualified…
HAZWOPER training for ammonia refrigeration response
A cold-storage employer asked what HAZWOPER training was needed for possible ammonia releases. OSHA said an exemption from some waste-facility provisions did not automatically remove…
Measuring minimum illumination at construction sites
A construction office asked how to understand the foot-candle unit used in OSHA's site lighting rule. OSHA said illumination varies with the light source and surroundings, so the level at the work…
Hazard communication for chemicals in office humidifiers
An engineer asked whether the Hazard Communication Standard covers chemicals added to office humidification systems. OSHA said maintenance staff and others who handle or store the chemicals may be…
Pesticide containers and hazard communication labels
An OSHA regional office asked whether an unlabeled pesticide container could be cited under the Hazard Communication Standard. OSHA said a proven EPA-regulated pesticide label issue belongs with…
A pre-vesting 'sign-on bonus' advance is a debt, not earned wages, so an employer cannot deduct its unearned portion from an employee's final paycheck even with written authorization
Counsel described a $5,000 sign-on bonus paid at the start of employment and earned incrementally over five months, with the employee's written authorization to deduct any unearned portion from the…
Carcinogen warnings on fibrous glass product labels Unknown
A requester questioned cancer warnings on fibrous glass products. OSHA said its 1991 review of scientific literature supported an appropriate label warning that fibrous glass may cause lung cancer…
Posting the OSHA workplace notice
A congressman asked whether a constituent had to display workplace posters mentioned in business mail. OSHA said its regulation requires every covered employer to post the official OSHA notice…
Correction to UCX audit compliance guidance Withdrawn
ETA warned state unemployment agencies that an OMB audit supplement used outdated eligibility criteria for unemployment compensation for former service members. The letter printed the criteria ETA…
Disaster unemployment benefit amounts, April to June 1991 Unknown
ETA supplied state average weekly benefit amounts to use when calculating disaster unemployment assistance for major disasters from April through June 1991. Its attachment listed each jurisdiction's…
Employer inquiries about the Multiple Worksite Report Unknown
ETA alerted state unemployment insurance tax offices that employers might ask them about the new quarterly Multiple Worksite Report. State administrators were to equip tax staff to answer general…
Personal-attendant exemption (IWC Order 15) does not cover workers who administer medication or take vital signs
This is a follow-up letter clarifying an earlier DLSE opinion about whether "Respite Workers" who assist home-care clients qualify as exempt "personal attendants" under IWC Wage Order 15's…
Shielding of drive lines on pivotal sprinklers and an interpretation of the words "guarded by location".
A sprinkler operator asked whether drive lines on pivotal irrigation systems needed shielding and what OSHA meant by "guarded by location." OSHA said the shafts could be treated as guarded by…
Implementation of a comprehensive chemical hygiene plan for lab operations
A law firm asked whether an employer could use one comprehensive chemical hygiene plan for all laboratory operations and satisfy OSHA’s laboratory and hazard communication requirements. OSHA said…
Overtime for temp-agency respiratory therapists placed at multiple hospitals with different workweeks in one week
A staffing agency placing respiratory therapists at various hospitals asked DLSE how overtime applies when the same worker is placed at different hospitals with different adopted workweeks (e.g., 3…
Rollover protective structures for material handling equipment
A law firm asked whether trenchers and similar crawler equipment needed rollover protective structures under OSHA’s construction standard. OSHA said the depicted trenchers required ROPS when used in…
Time and resources needed to comply with Lab Standard is justifiable
A member of Congress asked OSHA to respond to a constituent’s concern that the Laboratory Standard required too much time and money. OSHA said the rule was necessary and feasible, allowed…
Extension Cords Connected to Permanent Wiring of a Construction Site Building
A Virginia OSHA official asked whether extension cords connected to a construction building’s permanent wiring counted as temporary wiring and needed protection. OSHA answered yes to both questions:…
Procedures for release of 1990 unemployment insurance quality-control data Withdrawn
ETA directed state unemployment agencies to freeze their 1990 quality-control data on April 26, reconcile annual reports, and release their results by June 28, 1991. It specified report formats,…
Definition of Reasonable Diligence as stated in 1910.1096(d)(1).
A senator asked when an employer’s knowledge of elevated radon in a surrounding area created a duty to survey the workplace. OSHA said the answer depended on the facts and was not triggered by a…
Retesting when audiogram shows employees have suffered STS shift
An occupational audiologist asked how soon an employer must retest an employee after an annual audiogram shows a standard threshold shift. OSHA said the retest must be completed within 30 calendar…
Self-centering controls will be required on overhead bridge and container handling gantry cranes only. Unknown
An engineer asked which marine-terminal cranes had to use self-centering operating controls. OSHA said 29 CFR 1917.45(f)(1)(ii) applied only to overhead bridge and container handling gantry cranes,…
Acceptable use of the presence sensing device
A mill operator asked whether a presence-sensing light curtain could serve as a safety control under OSHA’s mill-guarding rule. OSHA said a tested and listed light barrier could replace or support…
Work permits in lockout/tagout standard requirements
A chemical company asked whether work permits could satisfy parts of OSHA’s lockout/tagout procedure requirements. OSHA said a documented generic procedure could be supplemented by required permits…
Use of Blood Carboxyhemoglobin to Document Employee Exposure to Carbon Monoxide Unknown
An OSHA regional office asked whether blood carboxyhemoglobin levels could establish workers’ carbon monoxide exposure when air measurements were unavailable. OSHA said the blood result could not…
Questions and Answers on the New Penalty System. Unknown
OSHA sent regional offices answers to staff questions about its then-new penalty system. The answers covered informal conferences, good-faith reductions, recordkeeping penalties, and how older…
Clarification of OSHA Instruction CPL 2.45B CH-1. Unknown
OSHA clarified internal inspection instructions after old references to records-only inspections remained in its field manual. It said programmed safety inspections from the register should be…
Compliance with 1910.147 using the new Block-Out safety product line. Unknown
A manufacturer asked whether its lockout products met OSHA’s hazardous-energy control standard. OSHA said the submitted information was insufficient for a complete compliance decision, pointed to…
Separate line for a full body harness Unknown
An engineer asked whether workers raised in body harnesses by a winch needed a separate safety line and whether the winch line could protect someone climbing a fixed ladder. OSHA said a worker…
MSDS requirements for scrap materials
A consultant for scrap recyclers asked OSHA to review hazard determinations and material safety data sheets for scrap commodities. OSHA said hazard information had to reach all downstream employers…
When a collective bargaining agreement expires, later events may end its overtime exemption from the expiration date
In a dispute involving NBC and NABET, DLSE explained that expiration of a collective bargaining agreement alone does not immediately end the wage orders' overtime exemption, because the parties may…
Jurisdictional Issue - Southwest Transportation. Unknown
An OSHA regional office asked which agency handled a truck-loading safety dispute. OSHA said loading and unloading at destination points fell within its jurisdiction, while readjusting and securing…
Non-finishing spraying of contact cement to wood or to laminae
A building contractors’ association asked whether OSHA’s spray-finishing standard covered spraying contact cement on wood and laminate for bonding rather than finishing. OSHA said the operation fell…
Occupational noise exposure limits Unknown
An equipment company asked whether a telephone product standard allowed sound levels above OSHA’s workplace noise limits. OSHA said some product-standard levels exceeded its continuous-noise limit,…
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.
- Check the status before relying: Every page shows whether the document is still active or has been superseded, rescinded, or withdrawn, and when that status was last verified.
- Guidance, not law: These documents explain the agency's position but bind no court, and the agency can change its view. The official document linked on every page is the authoritative source.
- Research across states: Compare how different states treat the same question, from overtime and travel time to tips and independent-contractor status.
Browse guidance by state
This library covers 8 states plus federal guidance so far. Every document is checked against the agency's official source before it is published, so states are added as their labor departments' guidance is verified, not all at once. If your state is not listed yet, its labor department's own site is the place to check.