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

Construction electrical rules for electric utilities

An electric utility association asked OSHA to withdraw or stay revised construction electrical rules. OSHA declined a broad stay, explaining that the installation rules generally addressed new…

1986-10-03 Opinion Letter October 3, 1986
US

Drill bits and the hazard communication article exemption

A drill-bit maker asked whether its products were exempt as articles under OSHA's hazard communication rule. OSHA said drill bits would usually qualify if normal use did not expose downstream…

1986-10-02 Opinion Letter October 2, 1986
US

Hazard communication labels and data sheets for a new manufacturer

A prospective floor-finish manufacturer asked what OSHA's hazard communication rule required. OSHA described the written program, labels, material safety data sheets and training required of covered…

1986-09-26-0 Opinion Letter September 26, 1986
US

One-day supply of flammable ink and adhesive Unknown

A regional office asked how flammable inks and adhesives used at a packing plant fit OSHA’s flammable liquid rules. OSHA said containers needed for a day’s operations were in use rather than stored,…

1986-09-26 Opinion Letter September 26, 1986
US

Aisle spacing for flammable-liquid warehouse storage

A company's lawyer asked how flammable-liquid storage aisle rules applied at two warehouses. After visiting, OSHA said one aisle-spacing shortfall was de minimis in light of the facilities'…

1986-09-19 Opinion Letter September 19, 1986
US

Labeling duties of hazardous-chemical wholesalers

A member of Congress asked how OSHA's chemical-labeling rule applied to wholesalers and distributors. OSHA said shipped containers needed identity, hazard warnings and responsible-party information.…

1986-09-16 Opinion Letter September 16, 1986
CA

A quitting employee generally must return to the workplace to collect final wages under Section 208

A retailer asked DLSE to issue an Interpretive Bulletin clarifying Labor Code Section 208's requirement that wages of a discharged employee be paid at the place of discharge, and that a quitting…

1986.09.15 Opinion Letter September 15, 1986
US

Fire-extinguisher training and employee evacuation choices

A utility asked whether its fire-response and employee education program met OSHA's extinguisher rules. OSHA described three choices: evacuate everyone, designate trained users while others…

1986-09-12 Opinion Letter September 12, 1986
US

Miami firefighters insurance fund as governmental Unknown

EBSA said the Miami firefighters insurance fund was a governmental plan excluded from ERISA Title I because it covered city employees and retirees and received substantial city funding. Adding other…

Advisory Opinion 1986-24A Opinion Letter September 9, 1986
US

Palm Beach County firefighters insurance fund Unknown

EBSA said the Palm Beach County firefighters insurance fund was a governmental plan excluded from ERISA Title I on the described coverage and county funding. Extending coverage to another employer’s…

Advisory Opinion 1986-23A Opinion Letter September 9, 1986
US

West Palm Beach firefighters benefit fund Unknown

EBSA said the West Palm Beach firefighters benefit fund was a governmental plan excluded from ERISA Title I because it covered city employees and retirees and received substantial city funding.…

Advisory Opinion 1986-22A Opinion Letter September 9, 1986
US

Carcinogen warnings on formaldehyde product labels

OSHA told regional staff how to assess formaldehyde product labels under the hazard communication rule. It said valid positive studies supported warnings about potential cancer risk and that such…

1986-09-09 Guidance September 9, 1986
US

Longspan bridging for steel joists and trusses Unknown

A steel joist manufacturer asked how OSHA’s longspan bridging rule applied. OSHA said “longspan” meant any joist or truss at least 40 feet long, beyond the industry’s product naming; a later…

1986-09-05-2 Opinion Letter September 5, 1986
US

Mixing tube and coupler scaffold components Unknown

A requester asked whether a tube and coupler scaffold could use components made by two companies. OSHA said mixing manufacturers was not prohibited if the scaffold complied with all applicable…

1986-09-05-1 Opinion Letter September 5, 1986
US

Guarding narrow scaffolds four to ten feet high Unknown

A regional administrator asked how the minimum horizontal dimension and guarding rule applied to scaffolds four to ten feet high. OSHA said the dimension referred to the platform and that the…

1986-09-05-0 Opinion Letter September 5, 1986
US

Testing of single-point suspension scaffold winches Unknown

A scaffold equipment maker asked whether manually operated winches tested by a laboratory other than the two named in OSHA’s rules could be used. OSHA said the arrangement described appeared to be a…

1986-09-05 Opinion Letter September 5, 1986
US

Batterymarch incentive fees for plan investment management Unknown

EBSA said Batterymarch’s described performance fee would not by itself violate ERISA sections 406(b)(1) or (b)(2). It would not rule out violations during operation, and independent plan fiduciaries…

Advisory Opinion 1986-21A Opinion Letter August 29, 1986
US

BDN incentive fees for plan investment management Unknown

EBSA said BDN’s described performance fee would not by itself violate ERISA sections 406(b)(1) or (b)(2). It declined to rule out operational conflicts, and plan fiduciaries had to evaluate and…

Advisory Opinion 1986-20A Opinion Letter August 29, 1986
US

Guardrails and hoists on two-point suspension scaffolds Unknown

A scaffold manufacturer asked about guardrails attached to platforms rather than hangers and about a hinged two-platform system suspended by three hoists. OSHA said the rail arrangement could be…

1986-08-29-0 Opinion Letter August 29, 1986
US

Brake rules for older earthmoving scrapers

A federal contracting officer asked whether construction brake rules applied to earthmoving scrapers made before 1972. OSHA said the applicable requirements covered the equipment regardless of…

1986-08-29 Opinion Letter August 29, 1986
US

St. Agnes medical center benefit plans as church plans Unknown

EBSA said the St. Agnes Medical Center pension and welfare plans were church plans excluded from ERISA Title I on the submitted facts. It suggested correcting plan materials that stated ERISA rights…

Advisory Opinion 1986-19A Opinion Letter August 22, 1986
US

Facial hair and tight-fitting respirator seals

A requester asked whether workers with facial hair could use a particular tight-fitting air mask. OSHA said thick hair where the mask meets skin prevents the required seal, so an employer could not…

1986-08-18-0 Opinion Letter August 18, 1986
US

Exposure limits listed on material safety data sheets

A manufacturer asked whether it could list only its most conservative exposure limit on material safety data sheets. OSHA encouraged disclosure of all known limits, but said the sheet had to include…

1986-08-18 Opinion Letter August 18, 1986
US

Timing of unemployment trust fund transfers Unknown

ETA restated target timing for transferring state unemployment receipts to the trust fund and drawing money for benefit payments. Current status is unconfirmed.

UIPL No. 54-86 Guidance August 15, 1986
US

Quality-control program questions and answers Unknown

ETA answered state questions about the newly implemented unemployment quality-control program, including investigation methods and data handling. Current status is unconfirmed.

UIPL No. 52-86 Guidance August 14, 1986
US

Hazard warnings for shipped printing inks

A printing-ink trade group asked how OSHA's hazard communication rule applied to labels. OSHA said shipped hazardous chemical containers needed identity, appropriate hazard warnings and…

1986-08-13 Opinion Letter August 13, 1986
US

Vehicle components as hazard communication containers

A truck manufacturer asked whether chemical-label rules applied to vehicle components that held operating fluids. OSHA said a radiator, engine or battery was not itself a container requiring a…

1986-08-11 Opinion Letter August 11, 1986
US

Chromate salts and carcinogen information on safety sheets Unknown

A chemical company asked whether sodium and potassium chromate and dichromate salts met the hazard communication rule’s carcinogen definition. OSHA said its reviewed sources did not then classify…

1986-08-05 Opinion Letter August 5, 1986
CA

IWC uniform-maintenance requirements are not preempted by the NLRA, even under a collective bargaining agreement

A defense contractor's senior counsel argued that the Industrial Welfare Commission Orders' requirement that an employer maintain uniforms it requires interferes with collective bargaining and is…

1986.07.31 Opinion Letter July 31, 1986
US

Concrete trowel handle shutoff after release

A manufacturer asked whether its safety switch met the construction rule for power concrete trowels. OSHA said the rule aimed to stop handle rotation after an operator let go. A centrifugal switch…

1986-07-29 Opinion Letter July 29, 1986
US

COBRA unemployment compensation amendments

ETA explained 1986 federal amendments allowing benefit offsets to recover overpayments, changing trade benefits and FUTA coverage, with attached interpretation and draft state-law language. ETA…

UIPL No. 50-86 Guidance July 21, 1986
US

Existing exit signs with smaller lettering Unknown

A requester asked about the size of exit sign letters in an existing building. OSHA said certain externally lit signs with 4½-inch letters could be treated as de minimis deviations if the building…

1986-07-18 Opinion Letter July 18, 1986
US

Splicing construction extension cords with heat-shrink covers

An electrical contractor asked whether heat-shrink covers could insulate splices in extension cords. OSHA said the covers were acceptable if the splice met the cited construction electrical rules…

1986-07-16 Opinion Letter July 16, 1986
US

UCFE student-worker eligibility and agency notices Unknown

ETA directed states to review UCFE claims from student workers under state law and correct agency notice and follow-up procedures identified in a GAO audit. Current status is unconfirmed.

UIPL No. 49-86 Guidance July 11, 1986
US

Visibility of hazard labels on shrink-wrapped pallet bags

A manufacturer asked whether labels hidden under shrink wrap on palletized chemical bags satisfied the hazard communication rule. OSHA said the label had to be visible before workers could be…

1986-07-02-0 Opinion Letter July 2, 1986
US

Carbon black in fingerprint powder safety data sheets

A fingerprint-powder maker asked how OSHA's hazard communication rule treated carbon black. OSHA said carbon black was a hazardous chemical because it had an exposure limit, so relevant hazards…

1986-07-02 Opinion Letter July 2, 1986
US

Consumer hand soap under hazard communication rules

A soap company asked whether borax hand soap fell under OSHA's hazard communication rule. OSHA said a finished consumer product was exempt when workers used it as a typical consumer would. It…

1986-06-30 Opinion Letter June 30, 1986
US

Deadline to notify workers of a hearing threshold shift

A requester asked when the hearing-conservation rule's 21-day notice clock began after an audiogram showed a standard threshold shift. OSHA said the clock started when the shift was determined, not…

1986-06-25 Opinion Letter June 25, 1986
US

Extended-benefit charges on combined-wage claims Unknown

ETA clarified how states should bill and allocate combined-wage extended-benefit charges during the 1986 reduction in federal reimbursement. Current status is unconfirmed.

UIPL No. 40-86 Guidance June 22, 1986
US

Compliance of a welding helmet with eye-protection rules

A helmet maker asked whether employers could use its welding helmet in place of equipment specified by OSHA's welding rules. OSHA said the available information showed equivalent protection when the…

1986-06-20 Opinion Letter June 20, 1986
US

Safety data sheets for blended waste-derived fuel oil

A waste-oil processor asked whether fuel oil blended with solvents needed a material safety data sheet. OSHA said a sheet was required when the product was sold to covered manufacturers and use…

1986-06-17 Opinion Letter June 17, 1986
US

Military reenlistment bonuses and UCX wages

ETA explained that military reenlistment bonuses are not federal military wages for calculating unemployment compensation for ex-servicemembers. ETA still lists the letter as continuing.

UIPL No. 38-86 Guidance June 12, 1986
US

St. Francis Hospital employee plans as church plans Unknown

EBSA said employee benefit plans maintained by a Catholic religious order for St. Francis Hospital workers were church plans excluded from ERISA Title I on the stated facts. The opinion concerns…

Advisory Opinion 1986-18A Opinion Letter June 10, 1986
US

Labels and data sheets for bulk scrap-metal shipments

A scrap-industry group asked whether hazard labels could be mailed separately instead of accompanying every bulk shipment. OSHA said no: label information had to travel with each shipment, either on…

1986-08-11-0 Opinion Letter June 6, 1986
US

Persistent hearing threshold shift and baseline audiograms

An audiologist asked what OSHA meant by a persistent standard threshold shift in hearing tests. OSHA said it meant a shift confirmed by a later audiogram. The rule permitted, but did not require, a…

1986-06-04-0 Opinion Letter June 4, 1986
US

Carcinogenicity entries on material safety data sheets

OSHA circulated an interpretation to its regional offices about carcinogenicity entries on material safety data sheets. It said the rule required an affirmative carcinogen indication when applicable…

1986-05-28 Guidance May 28, 1986
US

Hazard communication duties of scrap-metal dealers

A recycling association asked OSHA to exempt non-manufacturing scrap dealers from the hazard communication rule. OSHA said they were distributors and had to pass on labels and material safety data…

1986-05-23 Opinion Letter May 23, 1986
CA

Car allowance is a business expense, not vacation pay, absent a specific agreement

A personnel coordinator asked DLSE whether a car allowance must be included when calculating accrued vacation pay owed to terminated employees. DLSE responded that, absent a specific agreement…

1986.05.20 Opinion Letter May 20, 1986
US

Food-stamp overissuance withholding from UI

ETA explained when and how states may withhold unemployment benefits to recover food-stamp overissuances and the order of competing deductions. ETA still lists the letter as continuing.

UIPL No. 37-86 Guidance May 19, 1986
US

Manhole access through concentric concrete cones Unknown

A concrete supplier asked whether OSHA allowed workers to enter underground workplaces through concentric manhole transition cones. OSHA said it did not require eccentric cones or prohibit entry…

1986-05-13 Opinion Letter May 13, 1986
US

Special state funds for Title XII interest

ETA clarified when a state may use a special fund outside its unemployment fund to pay interest on Title XII advances. ETA still lists the letter as continuing.

UIPL No. 30-86 Guidance May 12, 1986
US

OSHA jurisdiction over dormitory smoking and worker exposure

A dormitory resident asked whether OSHA set ventilation limits for rooms shared with smokers. OSHA said it did not regulate residential ventilation and had no smoking-specific regulation. It…

1986-05-07 Opinion Letter May 7, 1986
US

Carcinogen labeling for solvent-refined petroleum oils

A refiner challenged OSHA's earlier hazard-label interpretation for solvent-refined oils. OSHA agreed that the cited studies did not show carcinogenicity for the naphthenic oils in question and…

1986-05-06 Opinion Letter May 6, 1986
US

Cancer-warning labels on polyvinyl chloride products

A plastics-industry lawyer asked whether polyvinyl chloride products needed cancer warnings. OSHA said resin that still required melting or final molding had to carry the label required by its vinyl…

1986-04-30 Opinion Letter April 30, 1986
US

Schedule A reporting of excess broker commissions Unknown

EBSA said excess insurance broker commissions calculated using employee benefit plan contracts had to be reported proportionately on Form 5500 Schedule A. The exception for agency-management…

Advisory Opinion 1986-17A Opinion Letter April 28, 1986
US

Air-line couplings for supplied-air respirators

An employer asked whether a supplied-air respirator system could share couplings or lines with other gases. OSHA said breathing-air couplings had to be incompatible with nonrespirable gas outlets…

1986-04-24 Opinion Letter April 24, 1986
US

Use of the M-17 military gas mask by civilian workers

A state safety official asked whether civilian workers could use surplus M-17 military gas masks. OSHA said the mask lacked the required approval and could not be used for those workers, and it saw…

1986-04-21 Opinion Letter April 21, 1986
US

Guardrail bracket spacing on flying forms Unknown

An equipment company asked whether flying form guardrail brackets could be spaced 14 feet apart. OSHA said that spacing was permissible if the rail system offered protection equivalent to brackets…

1986-04-17 Opinion Letter April 17, 1986
US

Refinery amine absorber vessel cracking advisory

OSHA alerted regional staff to cracking and possible catastrophic failure in refinery amine absorber vessels after a fatal explosion. It cited preliminary testing and industry surveys, pointed to…

1986-04-11 Guidance April 11, 1986
US

Union leader support fund outside ERISA plan definition Unknown

EBSA said a union support fund giving need-based subsistence assistance to leaders dismissed in retaliation did not provide benefits described in ERISA section 3(1) or 3(2), so it was not an ERISA…

Advisory Opinion 1986-16A Opinion Letter April 10, 1986

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