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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Broker loans to plans outside securities trades Unknown
EBSA said the PTE 75-1 credit exemption did not cover broker loans to benefit plans that did not arise directly from specific securities purchases, and ERISA’s service exemption did not extend to…
Oil-lubricated compressors and safety data sheets
A compressor manufacturer asked whether it had to provide material safety data sheets for oil-lubricated compressors or their compressed air. OSHA said the compressors were exempt articles because…
Reissued UI internal security risk-analysis guide Unknown
ETA transmitted a previously omitted volume of its optional technical assistance guide for state UI security risk analyses. Current status is unconfirmed.
Crane-suspended work platforms under construction rules Unknown
A regional administrator asked about workers using a platform suspended from a lattice or hydraulic crane boom. OSHA said it interpreted the construction crane rule to permit suspended work…
UCFE claims processing and overpayment recovery Unknown
ETA reissued and clarified claims-processing and overpayment recovery procedures for unemployment compensation for federal employees. Current status is unconfirmed.
Hazard labels and data sheets for carbide cutter teeth
A stump-removal equipment maker asked about hazard labels and material safety data sheets for carbide-tipped cutter teeth that customers grind. OSHA said labels for solid metal teeth could be sent…
Recirculating air from paint spray booths Unknown
A body shop owner asked whether filtered paint booth exhaust could be recirculated to save heat. OSHA said its spray-finishing rule prohibited recirculation, while a compliant workplace using the…
Blank sections on material safety data sheets
OSHA field staff asked how to handle blank blocks on material safety data sheets under the hazard communication standard. OSHA said preparers should use words showing information is unavailable or…
Pre-existing, firm-wide sabbatical programs get a narrow exception from Suastez
An attorney followed up on DLSE's July 13, 1987 letter (1987.07.13-1) to ask about a sabbatical leave program offered to all employees of a firm, not just senior managers. DLSE reaffirmed that a…
Distributor duties under expanded hazard communication rule
A lawyer asked whether earlier hazard communication interpretations survived the 1987 expansion of the standard. OSHA said they did, but distributors with exposed employees also needed data sheets,…
Retention of superseded material safety data sheets
A printing industry association asked what to do with superseded material safety data sheets for mixtures. OSHA said a prior sheet could be discarded if a new sheet covered the same hazardous…
Lift-slab construction after the Bridgeport collapse
After a lift-slab building collapse, OSHA told its regional offices it had asked construction firms to verify lifting-system components and obtain an engineer's progressive-failure analysis before…
Four-worker limit for crane-suspended work platforms Unknown
A contractor asked to carry more than four workers in crane-suspended platforms that it said were large and strong enough for its crews. OSHA said platform strength alone did not provide the same…
Temporary lighting strings at construction sites
A construction company asked whether manufactured temporary lighting strings met OSHA's construction wiring rules. OSHA said open wiring was allowed for temporary lighting circuits and listed or…
Approval of electrical equipment under construction standards Unknown
OSHA clarified the approval requirement for electrical equipment in its construction standards. It said the wording differed from the general industry rule without intending to expand testing…
Horns and reverse alarms on bulldozers
A construction trade association asked how the horn requirement differs from an audible reverse alarm and whether a bulldozer can use an alarm or signaler instead. OSHA said the horn provides a…
Quality-control questions and answers, Change 1 Unknown
ETA answered state agencies’ questions about unemployment quality-control procedures and supplemented UIPL 08-87 with an attached question-and-answer document. Current status is unconfirmed.
Target organs and chemical hazards under hazard communication
A lawyer asked how the hazard communication standard defined target organs and chemical hazards. OSHA explained that a chemical may cause its main toxic effects in particular organs, pointed to data…
Art materials and hazard communication duties
An art-materials trade association asked how OSHA's hazard communication standard applied to its members. OSHA said consumer-product labeling rules displaced only OSHA labeling duties, while other…
Respirators for contractors and business visitors
A company asked who had respiratory-protection duties when contractors or business visitors needed respirators at its plant. OSHA said each worker's employer was responsible for its own employees,…
Hazard determination in a paint-labeling guide
A paint industry association submitted a health-effects labeling guide for OSHA review. OSHA said the guide could help employers make hazard determinations, but compliance would still depend on the…
Federal Service Contract Act vacation rules are a floor, not a ceiling, under California law
The U.S. Department of Energy's Assistant Chief Counsel asked DLSE about vacation-benefit obligations for federal Service Contract Act contractors operating in California. DLSE's Chief Counsel…
Representative asbestos exposure monitoring in construction
An asbestos contractor asked how many employee samples were needed for representative monitoring. OSHA said the rule set no universal number; employers could sample everyone or employees reasonably…
Interim enforcement of bloodborne disease hazards Unknown
OSHA gave regional staff interim guidance for complaints about healthcare workers’ exposure to AIDS, hepatitis B, and other bloodborne diseases. It told staff to consider existing protective…
Responsibility for material safety data sheet accuracy Unknown
OSHA addressed whether downstream users could be cited for inaccuracies or omissions in material safety data sheets. It said only the manufacturer or importer that prepared or obtained the sheet was…
No California exemption from daily overtime for federal Service Contract Act employees
A federal contractor's human resources manager asked whether California exempts employees working under the federal Service Contract Act and Contract Work Hours and Safety Standards Act from the…
Chromium in photocopier toner and hazard communication
A company asked whether a competitor's photocopier toner containing chromium needed hazard warnings. OSHA had not completed its investigation, but said that if the toner contained hexavalent…
Horns and reverse alarms on construction equipment
A contractors' association asked about horns and backup alarms on construction equipment. OSHA said bidirectional machines needed an operable horn sounded as needed, and discussed separate…
Steel coils and the hazard communication article exemption
A steel producer asked whether coils qualified as exempt articles and how to fill in OSHA's material safety data sheet form. OSHA said article status depended on foreseeable downstream chemical…
Roof perimeter protection and powered platform inspections Unknown
An engineer asked whether older buildings needed roof perimeter protection and whether rarely used powered platforms needed inspection every 30 days. OSHA said the fall protection rules applied to…
Access ladders for tubular metal scaffolds Unknown
A regional administrator asked how ladder rules applied to access for tubular metal scaffolds. OSHA said a properly attached portable metal ladder could reach a 100-foot scaffold platform without…
Assigning safe working loads to ship cargo gear Unknown
OSHA addressed how its maritime cargo-gear rules should be applied when ship gear is used in union purchase. It directed field staff to refrain from calculating stresses or assigning safe working…
Formaldehyde cancer warnings before final rulemaking
A formaldehyde industry group asked OSHA to delay cancer-warning enforcement while a formaldehyde rule was pending. OSHA declined, saying existing evidence of human carcinogenicity already required…
Lead medical examinations and employee choice
A member of Congress asked whether an employer could require a worker to take a lead-related medical exam. OSHA said its standard required the employer to make an exam available at no cost, while…
Internal controls and risk analysis for state UI agencies
ETA revised its policy and guidance for state unemployment agencies on internal controls and risk analysis and rescinded UIPL 11-83. ETA still lists the letter as continuing.
Criteria for a sabbatical leave program to fall outside Suastez and Section 227.3
An attorney asked DLSE whether Labor Code Section 227.3 and the Suastez decision apply to a client's sabbatical leave program. DLSE opined that a true sabbatical, defined as paid leave for travel,…
Longevity bonuses in lieu of vacation at temporary service agencies, evaluated case-by-case for Suastez subterfuge
A temporary staffing company's president asked DLSE how the Suastez decision applies to temporary service agencies that pay longevity bonuses instead of offering vacation. DLSE explained that…
Radial-arm saw barrier guard conditions
OSHA field offices asked about an adjustable barrier guard on radial-arm saws. OSHA said the guard had to be positioned before each cut and fitted with side shields to prevent blade exposure. Used…
Mercury thermometer spill claims in an advertisement
OSHA responded to a thermometer advertisement that described strict spill-cleanup steps as OSHA requirements. OSHA said its mercury exposure standard did not prescribe cleanup procedures for glass…
Repayable quarterly 'yearly' bonus for nurses raises substantial-performance and deduction problems
An attorney asked DLSE about a bonus plan for nurses that pays a yearly bonus in quarterly installments, with repayment required if the employee does not complete a full year. DLSE said paying the…
Target-organ warnings on hazardous chemical labels
A lawyer asked whether hazard warnings on shipped chemical containers had to address target-organ effects. OSHA pointed to the standard's health-hazard definition, Appendix A and the rulemaking…
Hazardous-waste site training coverage
An environmental services company asked when hazardous-waste operations training applied to its work. OSHA said the training requirements applied if the work was at a covered cleanup or removal site…
Shoe-industry cancer listings and chemical labels
A business asked whether an IARC listing of boot and shoe manufacturing as associated with cancer meant all products needed carcinogen labels. OSHA said it listed the industry for inspector…
Fall protection at open second floors in housing construction
An OSHA regional office asked how to enforce fall protection at a fully decked, open-sided second floor during housing construction. OSHA said contractors usually erect the exterior partition first,…
Federal Service Contract Act vacation rules do not preempt California's Suastez proration requirement
An attorney for a security-guard contractor at the Oakland Army Base asked whether the federal Service Contract Act's vacation rules, which do not require proration, override California's Suastez v.…
Numerical hazard-label systems under hazard communication
A manufacturer asked whether OSHA endorsed an industry hazard-labeling system. OSHA said it endorsed no product, but clarified that systems using numerical severity ratings could be used if the…
Coverage of independent religious organizations
ETA interpreted FUTA coverage of religious organizations that are not affiliated with a church, convention, or association of churches. ETA still lists the letter as continuing.
Vantage Healthcare employee health plan status Unknown
EBSA said Vantage Healthcare’s employee health and dental plan was an ERISA welfare plan and, based on the requester’s representation that only Vantage employees participated, said it did not appear…
UCX eligibility for separated Air Force personnel
ETA gave states instructions for unemployment compensation eligibility determinations involving Air Force members separated after four or six years of service. ETA still lists the letter as continuing.
Bonus plans conditioned on active employment: substantial performance decided case-by-case
A law firm asked DLSE two questions about employee bonus plans: (1) whether a plan may require active employment on the bonus payment date, and (2) how the reason for termination affects…
Surgical laser program and OSHA standards
A health center asked OSHA about standards for a planned surgical laser program. OSHA said it had not issued specific criteria for employee laser use at that time, and pointed to an ANSI…
Estate distribution to a plan fiduciary in stock sale Unknown
EBSA said a violation of ERISA section 406(b)(3) generally would not be apparent merely because a fiduciary received a separate inheritance from an estate selling stock to the plan; the distribution…
Hobbie decision on religious disqualification from UI Unknown
ETA advised states of the Supreme Court’s Hobbie decision holding that denying benefits after a worker’s religious conversion violated the Free Exercise Clause. Current status is unconfirmed.
Lead chromate labeling under hazard communication rules Unknown
A regional administrator asked how OSHA’s hazard communication guidance applied to lead chromate labels. OSHA said the table listing carcinogens was general guidance and that the warning-label…
Numerical hazard labels in paint workplaces
A paint trade association asked whether its numerical hazard-labeling system met OSHA's in-plant labeling requirement. OSHA said the system could be acceptable when the overall hazard communication…
Trade adjustment assistance for bumped workers
ETA clarified when a worker displaced through a seniority bump qualifies for trade adjustment assistance. ETA still lists the letter as continuing.
Trade adjustment assistance during strikes and lockouts Unknown
ETA answered state agencies’ questions about the effect of strikes and lockouts on eligibility for trade adjustment assistance and trade readjustment allowances. Current status is unconfirmed.
Suastez does not apply where no paid vacation is offered at all
An attorney asked DLSE whether the Suastez decision applied to a client whose sales representatives received no paid vacation but could take unpaid time off by mutual agreement, continuing to earn…
Unemployment benefit overpayment offsets under Section 303(g) Unknown
ETA answered state agencies' questions about recovering unemployment benefit overpayments by offsetting benefits owed under another state or federal program. It explained when an agreement with the…
'Unlimited' executive vacation with approval still vests pro rata under Suastez
An attorney asked DLSE to review a client's executive vacation and sick-leave policy, arguing that no vacation was accruing because managers were told they had unlimited vacation "with approval."…
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.