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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Qualifications for annual bakery oven inspectors Unknown
A bakery oven service company asked whether its staff could perform annual inspections that the OSHA standard assigned to oven manufacturers' representatives. OSHA said qualified, knowledgeable…
Hazardous waste responder and hazard communication training Unknown
A service company asked about first responder awareness training under the hazardous waste rule and its overlap with hazard communication training. OSHA said training had to match workers' roles and…
Inspector General role in unemployment fraud investigations
ETA told state unemployment agencies that DOL's Inspector General would keep investigating fraud cases involving federal funds or state agency employees, but would return cases involving only state…
Glove box system for asbestos pipe insulation removal
An insulation contractor asked whether a glove box system met OSHA's asbestos removal requirements for pipe insulation. OSHA said the system appeared to meet the cited provision if other asbestos…
Diesel exhaust hazard disclosure on safety data sheets
OSHA sent diesel fuel manufacturers a notice about their material safety data sheets. It said manufacturers had to account for diesel exhaust during normal fuel use and report evidence of its…
Hazardous waste training for contaminated surface removal
A cleanup company asked whether HAZWOPER training applied when its crews removed contaminated concrete or coatings after spill recovery. OSHA said the work likely fell under the rule because cleanup…
Crystalline silica warning on insulation product labels
A product supplier asked whether crystalline silica released while cutting insulation could be disclosed on a material safety data sheet without a label warning. OSHA said potential exposure to more…
Tobacco smoke and workplace exposure limits Unknown
A requester asked what concentration of workplace tobacco smoke was too much. OSHA said it had no rule for tobacco smoke as a whole, but exposure limits for several components could apply; it listed…
HAZWOPER coverage for removal of petroleum storage tanks
A contractor asked whether HAZWOPER applies to removal of underground tanks that contain or once contained petroleum products. OSHA said petroleum products count as hazardous substances under the…
Voluntary real-property contribution to an employee stock ownership plan Unknown
An employer proposed to contribute unencumbered buildings to its employee stock ownership plan. EBSA said a purely voluntary contribution that did not replace a required cash contribution was not…
Profit-sharing plan trades in employer stock Unknown
A profit-sharing plan proposed employer-stock trades with parties in interest. A separate stockholder agreement set a formula price for other investors, but the plan’s trades would not be subject to…
Recapping used syringes under OSHA's bloodborne pathogen policy Unknown
A dentist asked about OSHA's prohibition on recapping syringes. OSHA said a revised 1990 enforcement directive allowed methods other than traditional two-handed recapping, including resheathing…
Fiscal 1990 sequestration and unemployment benefits Unknown
ETA explained how fiscal 1990 federal budget reductions affected unemployment programs, including the federal share of extended benefits. It described when states could reduce extended benefit…
Machine guarding and training on drilling rigs
A member of Congress asked which OSHA rules protect workers around drilling rig rotary equipment. OSHA said the general industry machine guarding rule applies to machinery without a more specific…
Chemical hazard labels and predicted downstream exposure
A chemical supplier asked whether it could leave health hazards off labels when it expected low exposure during downstream use. OSHA said potential exposure to a well-substantiated hazard generally…
Selective Service registration under the Job Training Partnership Act Rescinded
ETA told state and local Job Training Partnership Act programs how to check male applicants' Selective Service registration before enrollment. For applicants aged 26 or older who had not registered,…
Rolling compressed gas cylinders on their lower edge Unknown
A transportation company asked whether workers could move compressed gas cylinders by rolling them on their lower edge. OSHA said the incorporated Compressed Gas Association handling standard…
Guardrail loads and portable platform design Unknown
An engineer asked OSHA for additional guidance on handrails and guardrails on portable platforms. OSHA pointed to a National Bureau of Standards report and gave load and stability criteria for the…
First aid course review and draft training guidelines Unknown
A health system asked OSHA to certify its first aid course. OSHA said it had stopped reviewing first aid courses at the national office and that training should match the hazards at each workplace.…
Good cause for late unemployment quality-control case completion Unknown
ETA gave state unemployment agencies a way to explain why some 1989 quality-control investigations missed the 90-day completion target. Agencies had to analyze all delayed cases if there were 30 or…
Alternative hepatitis B vaccination doses and routes Unknown
A medical center asked whether low-dose or intradermal hepatitis B vaccination could count as standard recommended practice for employees in a research study. OSHA said it would not treat an…
Current consensus standards and power-transmission guarding Unknown
An engineer asked about guarding mechanical power-transmission equipment under an older OSHA standard and a newer consensus standard. OSHA said its adopted rule remained effective until revised, but…
Lower blade guards on radial arm saws Unknown
A saw manufacturer asked whether its lower blade guard met OSHA's radial arm saw rule. OSHA said the photographed guard appeared to meet the rule's intent and pointed to an earlier enforcement…
Chest X-ray retention under employee medical records rule
A hospital asked which employee chest X-rays must be retained under OSHA's medical records rule and whether films may be microfilmed. OSHA said the rule covers workers with qualifying hazardous…
Hazard communication and independent contractors in beauty salons
A member of Congress asked whether a salon with workers called independent contractors had to follow OSHA's hazard communication rule. OSHA said labels and contracts alone do not settle worker…
1989 budget acts and federal unemployment tax wages Unknown
ETA informed state unemployment agencies about 1989 federal-law changes affecting which employer payments counted as wages under the Federal Unemployment Tax Act. The attached explanation covers…
Industrial packaging machinery and electrical listing requirements
A packaging company asked whether industrial machines needed a testing laboratory listing. OSHA explained the rule's listed and labeled equipment definitions and said a custom-made machine for a…
Qualifications to inspect bakery ovens annually Unknown
A bakery oven specialist asked whether his background qualified him to perform annual inspections under a rule naming oven manufacturers' representatives. OSHA said the experience he described would…
ERISA exclusion for a California voluntary disability plan Unknown
An employer asked whether its California voluntary disability plan was outside ERISA Title I. EBSA said the plan, as then operated solely to provide state-mandated disability benefits, fell under…
Georgia insurance oversight of a physicians benefits trust Unknown
The request asked whether a physicians and hospitals benefits trust was a MEWA and whether state insurance rules could apply. EBSA said it was a MEWA subject to state regulation to the extent ERISA…
ERISA status of a fishing-industry group health plan Unknown
A fishing association asked whether its group health plan was an ERISA welfare plan under title I. EBSA could not decide whether the association was a bona fide employer group because actual…
1990 federal military remuneration schedule for UCX claims Unknown
ETA issued a revised federal military pay schedule for unemployment claims by former service members. State agencies were told to use the attached rates for first claims filed beginning with the…
Material safety data sheets from chemical distributors
A senator asked whether distributors must include a material safety data sheet with every chemical package. OSHA said manufacturers and distributors provide a sheet at initial shipment and when new…
Workplace drug testing results under the employee medical records access standard
An OSHA regional office asked whether workers and OSHA inspectors could access workplace drug test results under the employee medical records rule. OSHA said the rule covers drug test results only…
OSHA and motor carrier jurisdiction over tank car drivers and helpers
OSHA explained how motor carrier safety rules affect its authority over drivers and helpers. Where the motor carrier agency has exercised authority over a particular working condition, OSHA said it…
Training after a chemical spill at a manufacturing site Unknown
A manufacturer asked whether one HAZWOPER training paragraph alone covered employees cleaning up a spill discovered after hours. OSHA said the facts were insufficient for a definite answer and…
When small facilities may give emergency and fire plans orally
A trade association asked when emergency action and fire prevention plans must be written. OSHA said the threshold is 11 or more employees physically present at a facility at any time during the…
HAZWOPER training for police, firefighters, and incident commanders
A fire department asked what HAZWOPER training police officers, firefighters and incident commanders need. OSHA said duties determine the responder level: awareness-level workers must demonstrate…
Cleaning product safety claims and hazard communication duties
A member of Congress asked whether a cleaning product's claim to meet OSHA requirements amounted to an agency endorsement. OSHA said it does not set requirements for cleaning chemicals as products,…
Field sanitation training for farmworkers
A senator asked about field sanitation citations at a farm and the rule's hygiene instruction requirement. OSHA said employers must tell field workers why drinking water, handwashing and toilet use…
Expiration of interim crane personnel platform guidance Unknown
An OSHA regional official told compliance staff that interim guidance and temporary variances for anti-two-blocking cranes hoisting personnel had expired. The memorandum said the 1988 personnel…
Lockout rule coverage for manufactured home production Unknown
A manufactured housing association asked whether its members' plants were excluded from the lockout/tagout rule as construction. OSHA said employees engaged in manufactured home production under the…
Cartridge change intervals for dry cleaning respirators
An OSHA regional office asked how dry cleaners should use air-purifying respirators against perchloroethylene vapors. OSHA said cartridge change intervals must account for the highest expected…
Scaffold end-frame members used as ladder access Unknown
A safety consultant asked whether horizontal scaffold end-frame members could serve as ladder rungs. OSHA said they could if the manufacturer designed them for access and they met the stated…
Safety data sheets for consumer pesticides used at work
A pesticide manufacturer asked whether it could decline to supply a material safety data sheet when an institution uses a household product differently from a homeowner. OSHA said the…
Hazardous waste emergency response duties for generators
A waste generator asked how OSHA's emergency response rule applies alongside EPA's hazardous waste requirements. OSHA said the evacuation exception applies only when employees leave the site and…
Medical devices as articles under hazard communication
A medical supply group asked whether devices such as metal bed pans and crutches count as articles under OSHA's hazard communication rule. OSHA said they do when ordinary use poses no exposure…
Monthly certification deadline for Reed Act obligations Unknown
ETA supplied a due date omitted from UIPL 05-90. States setting aside Reed Act funds were told to certify new obligations and deobligations by the tenth business day of the following month and send…
Pharmaceutical drugs under the hazard communication standard
A safety consultant asked how OSHA’s Hazard Communication Standard applies to pharmaceutical drugs, including solid pills, package inserts, and IV bags. OSHA said solid drugs ready for direct…
Hazardous-waste-site training for perimeter and support workers
A hazardous-waste industry group asked whether clerical staff, support personnel, and delivery drivers working around a site must receive HAZWOPER training. OSHA said workers who stay outside…
State insurance oversight of a church association benefits trust Unknown
The request asked whether a church association’s self-funded employee benefits trust was a MEWA subject to state insurance law. EBSA said it was a MEWA because it covered workers of separate…
Approved alternate safety standards for federal agencies Unknown
OSHA reviewed alternate safety standards used by federal agencies and told regional staff which four remained approved in its records. It said other claimed approvals required an OSHA approval…
Asbestos training and medical surveillance as employment conditions
An OSHA regional office asked whether an employer may require asbestos training and medical surveillance as conditions of employment. OSHA said pre-employment conditions are outside its…
Georgia insurance oversight of a business association trust Unknown
The request asked whether a business association benefits trust was a multiple employer welfare arrangement. EBSA said the trust was a MEWA subject to state insurance regulation to the extent ERISA…
Emergency showers and eyewash facilities for formaldehyde work
A photographic manufacturers’ group asked how OSHA’s formaldehyde standard applies to photographic-processing facilities. OSHA said employers must provide emergency showers after splashes involving…
Contaminated soil discovered during construction excavation Unknown
A regional OSHA office asked whether contaminated soil found during a sewer construction excavation made the work a hazardous waste cleanup under HAZWOPER. OSHA said the described excavation was for…
California insurance oversight of the Associated Benefits Trust Unknown
California asked whether the Associated Benefits Trust was a multiple employer welfare arrangement. EBSA said the trust was a MEWA subject to state insurance regulation to the extent ERISA permits.…
Employer-directed travel time is hours worked in California with no federal-style 8-hour cap, unlike under the FLSA
An employer asked whether it complied with California law by paying only 8 hours of normal wages on days when employees were non-working passengers on planes or other transportation for 8 or more…
Retention of medical records for office workers
A medical center asked which medical records employers must retain under OSHA’s access standard. OSHA said orthopedic X-rays need not be retained unless they relate to employees exposed to toxic…
Carcinogen labeling for nickel in mixtures
A manufacturer asked whether nickel powder in a mixture must be included in hazard determinations and carcinogen labeling when it is not expected to become airborne. OSHA said a chemically bound…
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.