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

Decomposition products on material safety data sheets

An OSHA regional office asked when decomposition products belong on a material safety data sheet. OSHA said hazardous products formed during normal operations, such as hot-wire cutting, must be…

1989-02-17 Opinion Letter February 17, 1989
US

PRUCOL alien status and unemployment eligibility

ETA gave additional interpretation of aliens permanently residing under color of law for unemployment benefit eligibility under FUTA. ETA still lists the letter as continuing.

UIPL No. 01-86, Change 1 Guidance February 16, 1989
US

Labels for hazardous chemicals moved between company plants

A company asked whether chemicals sent from one of its plants to another require hazard labels. OSHA said hazardous chemicals moved between company facilities must be labeled, regardless of whether…

1989-02-16 Opinion Letter February 16, 1989
US

Safety data sheet duties for healthcare wholesalers

A lawyer asked whether a healthcare-products distributor could use the retail rule that provides material safety data sheets only on request. OSHA said the company’s sales to hospitals, clinics, and…

1989-02-15 Opinion Letter February 15, 1989
US

ERISA preemption of proposed Utah pharmacy restrictions Unknown

Utah asked whether proposed restrictions on third-party purchasers of prescription drugs could govern ERISA plans. EBSA said the proposal would be preempted insofar as it applied to covered employee…

Advisory Opinion 1989-01A Opinion Letter February 10, 1989
US

Inspection of rubber insulating equipment for electrical work

An electric utility asked which ANSI standards govern rubber protective equipment and how it must be inspected during use. OSHA listed the manufacturing standards for gloves, matting, blankets,…

1989-02-10 Opinion Letter February 10, 1989
US

Silica bound in rubber under hazard communication

A manufacturer asked whether crystalline silica bound in silicone rubber must appear on a material safety data sheet. OSHA said a hazardous ingredient is outside the standard if it cannot expose…

1989-02-08 Opinion Letter February 8, 1989
US

Former field sanitation worker-count interpretation Rescinded

OSHA once advised its regional offices how to count agricultural hand-labor workers for field sanitation coverage. The agency expressly rescinded this February 6 memo in its September 5, 1989…

1989-02-06-1 Opinion Letter February 6, 1989
US

Concrete and masonry limited access zones

OSHA responded to questions about its concrete and masonry construction standard, 29 CFR 1926.706. The memorandum addressed who must establish a limited access zone, when employers may be cited, how…

1989-02-06 Opinion Letter February 6, 1989
US

Unemployment insurance quality-control questions and answers, Change 3 Unknown

ETA answered state agencies' questions about unemployment insurance quality-control investigations and coding. It addressed how to verify claims and wages, conduct interviews, and record findings…

UIPL No. 08-87, Change 3 Guidance January 24, 1989
US

Hazard communication for portland cement

An employer asked why portland cement came with a material safety data sheet. OSHA said the cement maker identified eye and skin irritation hazards, so employers whose workers are exposed must make…

1989-01-23 Opinion Letter January 23, 1989
US

Distributor charges for material safety data sheets

A supplier association asked whether distributors may charge customers for material safety data sheets. OSHA said the rule does not bar charges before a hazardous chemical is shipped, but sheets…

1989-01-19 Opinion Letter January 19, 1989
US

Distributor responsibility for safety data sheet delivery

A veterinary distributors’ association asked whether a proposed system for sending material safety data sheets to downstream customers would satisfy OSHA’s rule. OSHA said the plan appeared capable…

1989-01-13 Opinion Letter January 13, 1989
US

Who may inspect bakery ovens

A member of Congress asked whether an outside professional could inspect bakery ovens for several employers. OSHA said ovens require twice-monthly inspections by an appointed, instructed bakery…

1989-01-06 Opinion Letter January 6, 1989
US

1988 family-support and housing amendments to unemployment data sharing

ETA explained how 1988 federal amendments affected state unemployment agencies' sharing of wage and claim information. The letter and its two interpretation attachments address child-support…

UIPL No. 11-89 Guidance January 5, 1989
US

IRA loan to a corporation linked to its owner Unknown

An IRA owner proposed lending account funds to a corporation in which he had an ownership interest. EBSA said the company was not a disqualified person solely through the specified employer or…

Advisory Opinion 1988-18A Opinion Letter December 23, 1988
US

Diesel fuel exhaust under hazard communication rules Unknown

A trucking association asked whether diesel exhaust fell under OSHA's hazard communication rule. OSHA said exhaust alone was not a covered chemical, but diesel fuel was, and known combustion hazards…

1988-12-22 Opinion Letter December 22, 1988
US

Union input on pension investment choices Unknown

A company and union proposed a committee to suggest communities for residential mortgage investments and nonprofit debt opportunities. Separately, the union could recommend avoiding investments in…

Advisory Opinion 1988-16A Opinion Letter December 19, 1988
US

ERISA preemption of Puerto Rico plan-funding limits Unknown

A requester asked whether Puerto Rico Act 17 could regulate how ERISA plans are funded through payroll deductions. EBSA said section 5 was preempted to the extent interpreted to limit, prohibit, or…

Advisory Opinion 1988-17A Opinion Letter December 9, 1988
US

Seat belt anchorage on off-highway construction vehicles Unknown

A construction employer asked how seat and seat belt anchorage provisions applied to off-highway jobsite vehicles. OSHA said the anchorage requirement was independent of the rule about firmly…

1988-12-06-0 Opinion Letter December 6, 1988
US

County hospital pension plan as a governmental plan Unknown

A county hospital asked whether its defined benefit pension plan was covered by ERISA Title I. The Department found the hospital to be a governmental agency or instrumentality and its plan a…

Advisory Opinion 1988-15A Opinion Letter December 5, 1988
US

Eligibility of certain noncitizens for unemployment benefits Unknown

ETA explained how work authorization and temporary resident status under federal immigration law affect unemployment eligibility. It distinguished availability for work from use of base-period…

UIPL No. 06-89 Guidance December 2, 1988
US

Live booms and controlled lowering when hoisting workers Unknown

A crane manufacturer asked about the personnel platform rule's live boom prohibition and controlled lowering requirement. OSHA said a boom lowered only by its brake was prohibited, while the load…

1988-11-29 Opinion Letter November 29, 1988
US

Hazard communication training for stevedores handling sealed cargo

A maritime employer asked OSHA to exempt stevedores who handle trailers carrying sealed hazardous cargo from hazard communication training. OSHA said the trailers count as sealed containers, so…

1988-11-17 Opinion Letter November 17, 1988
US

Fall protection for cable television ladder work Unknown

A cable television company asked about fall protection during service work from ladders. OSHA said employees working directly from a ladder more than four feet above ground had to use a safety belt…

1988-11-16 Opinion Letter November 16, 1988
US

Weighing outbound vehicle containers at marine terminals Unknown

A marine terminal asked whether closed containers carrying only vehicles qualified for a weighing exemption. OSHA said the cited rule exempted only open-type vehicle carrying containers, although it…

1988-11-15 Opinion Letter November 15, 1988
US

Hot-water capacity in temporary labor camps

An agency office asked what an adequate hot-water supply means under OSHA’s temporary labor camp rule. OSHA said capacity depends on the number of occupants and gave minimum recovery and storage…

1988-11-14 Opinion Letter November 14, 1988
US

Hazard labels on vehicles and workplace machines

A paper company asked whether lift trucks and machines containing hazardous chemicals need container labels. OSHA said vehicles and machine components are generally not containers under the Hazard…

1988-11-10 Opinion Letter November 10, 1988
US

Safety monitors on low-pitch roofing work Unknown

An OSHA regional office asked when a safety monitor could replace a physical fall protection system. OSHA said the then-current exception was limited to built-up roofing on low-pitch roof…

1988-11-08-0 Opinion Letter November 8, 1988
CA

Volunteers for religious/charitable organizations aren't employees, but paid staff get no religious-organization minimum-wage exemption

A Christian Science church group asked DLSE how the Industrial Welfare Commission Orders apply to employees of church offices and attendants in Reading Rooms. DLSE explained there is no minimum-wage…

1988.10.27 Opinion Letter October 27, 1988
US

Special trucks for moving compressed-gas cylinders

A safety-cap maker asked what OSHA means by a special truck for moving compressed-gas cylinders and whether its cap could replace one. OSHA said a special truck is a cart or vehicle that stably…

1988-10-24-0 Opinion Letter October 24, 1988
US

Appeal rights for ETA federal-assistance grantees Rescinded

ETA told federal-assistance grantees how to appeal a final audit determination when no statute or regulation established another appeal process. For those grants, ETA selected a hearing before the…

TEGL No. 2-88 Guidance October 21, 1988
US

Alarm devices versus automatic anti-two-blocking protection Unknown

A contractors' association asked whether alarms could satisfy the crane personnel platform anti-two-blocking requirement. OSHA said alarms depended too heavily on operator reaction time and did not…

1988-10-05-0 Opinion Letter October 5, 1988
US

Annual bakery-oven inspections by a qualified burner company

A burner company asked whether its personnel could conduct required annual inspections of bakery ovens at customer sites. OSHA said qualified representatives of an oven manufacturer who know the…

1988-10-03 Opinion Letter October 3, 1988
US

Child care assistance for unemployment claimants Unknown

ETA encouraged state unemployment offices to help claimants with child care responsibilities by providing relevant information and assistance. Current status is unconfirmed.

UIPL No. 60-88 Guidance September 28, 1988
US

State waivers for SAVE unemployment eligibility verification

ETA decided which state unemployment agencies could avoid the automated part of the SAVE immigration-status verification program in 1988. Six states received waivers and three did not; every state…

UIPL No. 59-88 Guidance September 28, 1988
US

Revised alien wage-credit interpretation

ETA revised its interpretation of when certain lawfully admitted temporary residents’ prior wages may count toward unemployment monetary eligibility. ETA still lists the letter as continuing.

UIPL No. 12-87, Change 1 Guidance September 28, 1988
US

Transfer of assets in a welfare-plan merger Unknown

A plan administrator proposed merging an employer's disability and medical plans and moving related assets and liabilities into the merged plan. EBSA said that transfer alone would not violate the…

Advisory Opinion 1988-14A Opinion Letter September 28, 1988
US

Crystalline silica carcinogenicity warnings under hazard communication

A stone-industry group asked OSHA to say crystalline silica should not be treated as a carcinogen for hazard communication. OSHA denied the request, citing scientific evidence and the standard’s…

1988-09-20 Opinion Letter September 20, 1988
US

Taut rope and chain guardrails on shipyard scaffolds Unknown

A shipbuilding association challenged OSHA's meaning of taut for rope or chain scaffold guardrails. OSHA disagreed and said guardrails meeting the criteria in its cited directive were taut under the…

1988-08-31 Opinion Letter August 31, 1988
US

Trustee compensation from pension and welfare plans Unknown

A requester writing for two plans asked whether a trustee could receive compensation from them while receiving full-time pay from a construction company. EBSA said the company’s ties did not bar…

Advisory Opinion 1988-13A Opinion Letter August 29, 1988
CA

Per-procedure pay to dialysis nurses is piece-rate work, not sales commissions, so it doesn't qualify for the commissioned-employee overtime exemption

Following up on 1984 and 1986 letters that had treated a client's dialysis nurses as commissioned employees exempt from overtime, an attorney asked DLSE to confirm that view still held. DLSE…

1988.08.29 Opinion Letter August 29, 1988
US

Public school money-purchase plan as governmental Unknown

A school system asked whether its money-purchase retirement plan was covered by ERISA Title I. EBSA said the plan was established and maintained by a Virginia public school agency for its employees…

Advisory Opinion 1988-12A Opinion Letter August 24, 1988
US

Bank trustee investment in premium-fee common funds Unknown

A bank asked whether plan assets could enter common trust funds with premium fees under an arrangement approved by independent plan decision-makers. EBSA said investment under the stated safeguards…

Advisory Opinion 1988-11A Opinion Letter August 17, 1988
US

Hazard communication exemption for waste samples sent to a lab

A safety consultant asked whether hazardous-waste samples sent to a lab for analysis lose their Hazard Communication Standard exemption. OSHA said samples sent as part of disposal preparation remain…

1988-08-17 Opinion Letter August 17, 1988
US

Dependent-care reimbursements and ERISA welfare-plan status Unknown

An employer paid or reimbursed workers for child care of their choice without sponsoring a specific center. EBSA said the program did not provide the type of benefit listed in ERISA section 3(1) and…

Advisory Opinion 1988-10A Opinion Letter August 12, 1988
CA

A vacation-accrual schedule that decreases in year two is not a reasonable acceleration policy under Suastez

Counsel for an employer asked DLSE to clarify a 1986 Interpretive Bulletin on vacation pay, describing a plan with no vacation accrual for the first 90 days, one week of vacation at the end of year…

1988.08.04 Opinion Letter August 4, 1988
US

Deadline to replace open-tip standpipe hose nozzles

A fire-protection company asked when open-tip nozzles on standpipe hose had to be replaced with shut-off nozzles. OSHA clarified that the deadline was by July 1, 1981, rather than sometime after…

1988-08-02 Opinion Letter August 2, 1988
CA

Reasonableness of a one-year vacation-accrual cap under Interpretive Bulletin 86-3

An attorney asked DLSE whether a one-year ceiling on vacation accrual would be a reasonable "use it or lose it" cap under Interpretive Bulletin 86-3. DLSE explained that caps on vacation accrual are…

1988.07.25 Opinion Letter July 25, 1988
US

Proof testing of synthetic web slings

An OSHA regional office asked whether a contractor could repeatedly proof test synthetic web slings above their rated load. OSHA said proof testing and certification generally belong to the…

1988-07-19 Opinion Letter July 19, 1988
US

Interim enforcement of hazard communication outside construction Unknown

OSHA told regional administrators how a court stay affected enforcement of the expanded Hazard Communication Standard in 1988. It said the stay applied to construction employers, while other…

1988-07-18 Guidance July 18, 1988
CA

Monthly bonus payments and how to calculate the overtime due on bonus pay

A retailer's regional personnel attorney asked DLSE whether a bonus can be paid on a monthly basis under Labor Code § 204. DLSE confirmed a bonus may be paid monthly if the plan defines it as earned…

1988.07.14 Opinion Letter July 14, 1988
US

Employee access to safety data sheets and written hazard programs

An employer asked whether it must provide employees’ representatives with safety data sheets and the written hazard communication program. OSHA said the first request for an exposure record must be…

1988-06-30 Opinion Letter June 30, 1988
US

Qualifications for hazardous waste safety trainers Unknown

A health services manager asked what qualifications instructors needed for interim HAZWOPER training. OSHA said the rule set no fixed degree or credential; instructors needed training at a higher…

1988-06-29-0 Opinion Letter June 29, 1988
US

Training for low-exposure hazardous waste site workers Unknown

A waste site services firm asked whether employees who did not disturb hazardous materials needed HAZWOPER training. OSHA said workers neither exposed nor potentially exposed did not need the cited…

1988-06-28-0 Opinion Letter June 28, 1988
US

Avoiding unsupported target-organ warnings on labels

An OSHA regional office asked whether a manufacturer could use the same broad list of target-organ hazards on every product in a line. OSHA said each listed hazard must be demonstrated by at least…

1988-06-27 Opinion Letter June 27, 1988
US

Direct-reading instruments and objective data at waste sites Unknown

A cleanup firm asked whether direct-reading instruments and objective data could satisfy interim HAZWOPER monitoring rules. OSHA accepted direct-reading tools for initial characterization if they…

1988-06-21 Opinion Letter June 21, 1988
US

Confidentiality and retention of occupational medical records

A lawyer asked how an employer can retain required employee medical records without learning unrelated medical details. OSHA said non-healthcare managers receive only occupationally relevant…

1988-06-16-1 Opinion Letter June 16, 1988
CA

Overtime on commissions paid alongside an hourly wage, and the semi-monthly payday rule for earned commissions

A payroll processor asked DLSE how to calculate overtime for an employee paid an hourly rate plus commissions. DLSE gave a worked example: divide commissions earned in the workweek by hours worked…

1988.06.15 Opinion Letter June 15, 1988
US

Carcinogen labels for IARC category 2B chemicals

A company asked whether chemicals classified by IARC as category 2B always need a cancer warning on their labels. OSHA said all relevant hazards belong on the material safety data sheet, but label…

1988-06-14 Opinion Letter June 14, 1988

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