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

United Way affiliate plans and audit waiver Unknown

EBSA treated the United Way affiliate arrangements as separate plans rather than one combined plan. Each individual plan could use the small-plan audit waiver if it had fewer than 100 participants…

Advisory Opinion 1983-21A Opinion Letter May 9, 1983
US

Military separation reasons and UCX eligibility Unknown

ETA explained how DD Form 214 narrative separation reasons affect unemployment compensation for ex-servicemembers. Current status is unconfirmed.

UIPL No. 25-83 Guidance April 27, 1983
US

Investment adviser reimbursement of direct expenses Unknown

EBSA said a related adviser’s services to a common trust could qualify for the service exemption if its conditions were met, but conflicted selection could still be self-dealing. Direct…

Advisory Opinion 1983-20A Opinion Letter April 27, 1983
US

Hinged rest platforms on fixed ladders Unknown

OSHA wrote a ladder manufacturer after learning it advertised a fixed ladder with a hinged rest platform as OSHA compliant. OSHA said its fixed ladder rule did not allow hinged platforms, except for…

1983-04-25-0 Opinion Letter April 25, 1983
US

Stop-loss insurance under affiliated-insurer exemption Unknown

EBSA said the described stop-loss contracts bought by health and disability plans could qualify as benefit-funding contracts under class exemption PTE 79-41. The opinion did not cover separate…

Advisory Opinion 1983-19A Opinion Letter April 21, 1983
US

Face-amount certificate deposits and ERISA exemption Unknown

The Department said ISA, a face-amount certificate company, was a bank or similar financial institution under ERISA's cited exemption and that its certificates were deposits. Whether the…

Advisory Opinion 1983-18A Opinion Letter April 15, 1983
US

Reporting FUTA credit-reduction discrepancies Unknown

ETA announced a two-year period for states to report apparent discrepancies in IRS collections of FUTA credit-reduction amounts. Current status is unconfirmed.

UIPL No. 24-83 Guidance April 14, 1983
US

Light-duty pneumatic staplers without release levers

An OSHA region asked about furniture-industry pneumatic staplers without safety release levers. OSHA said tools operating below 100 psi could be acceptable with pressure control, light-duty staples,…

1983-04-08-0 Opinion Letter April 8, 1983
US

Ryland health plan covered by ERISA Unknown

EBSA said Ryland’s employee health program was an ERISA welfare plan both before and after it became partly self-funded on August 1, 1981. The employer maintained the program for its employees and…

Advisory Opinion 1983-17A Opinion Letter March 29, 1983
US

Hearing conservation amendment and construction workers

A construction group asked whether the 1983 hearing conservation amendment covered construction employees. OSHA said it did not apply to construction or agriculture and pointed to the separate…

1983-03-29-0 Opinion Letter March 29, 1983
US

Retail paint thinner in approved plastic containers

A paint supplier asked about one-gallon plastic containers of paint thinner in a retail store. OSHA said the described Class II combustible liquid could be stored in approved plastic containers…

1983-03-29 Opinion Letter March 29, 1983
US

Power press brake guarding in job shops Unknown

An OSHA regional administrator asked how point of operation guarding requirements applied to power press brakes in job and model shops. OSHA said each setup needed evaluation and that safe distance…

1983-03-25 Opinion Letter March 25, 1983
US

Dental association IRA outside ERISA plan status Unknown

EBSA said an Equitable IRA offered to American Dental Association members was not an ERISA pension plan merely through the association because that association was neither an employer group nor an…

Advisory Opinion 1983-15A Opinion Letter March 22, 1983
US

Flammable glue spraying under spray-finishing rules

An OSHA region asked whether spraying glue before lamination was covered by the spray-finishing rule. OSHA said the rule’s broad use of finishing materials included that glue application, as well as…

1983-03-17 Opinion Letter March 17, 1983
US

Wisconsin bankers insurance trust and MEWA rules Unknown

EBSA could not determine whether active-member banks actually controlled the Wisconsin Bankers Association trust, so it declined a blanket single-plan ruling. It said each participating nonvoting…

Advisory Opinion 1983-14A Opinion Letter March 14, 1983
US

Denver firefighters retirement and death plan Unknown

EBSA said a firefighters association’s retirement and death benefit arrangement was both an ERISA pension and welfare plan. It was not a governmental plan because the city neither controlled it nor…

Advisory Opinion 1983-13A Opinion Letter March 14, 1983
US

Oregon trust company as bank under PTE 80-51 Unknown

EBSA said Capital Trust counted as a bank for class exemption PTE 80-51 when maintaining Real Estate Equity Fund II. It did not decide whether any particular investment met another exemption or…

Advisory Opinion 1983-12A Opinion Letter March 11, 1983
US

Fumigant sampling as employee exposure records

A longshore union asked whether fumigant grab samples were employee exposure records. OSHA said section 1910.1020 generally did not require employers to create records, but recorded sample results…

1983-03-01 Opinion Letter March 1, 1983
US

Safe access while assembling or dismantling scaffolds Unknown

A construction company asked five questions about access during scaffold assembly and dismantling. OSHA said continuous ladder access was not required during those tasks, but other safe access was;…

1983-02-25-0 Opinion Letter February 25, 1983
US

HYO and HYEX stock options and plan assets Unknown

EBSA said the Husky pension plans owned option rights, but stock and underlying corporate assets they might acquire later were not yet plan assets. Decisions to exercise or keep the options still…

Advisory Opinion 1983-11A Opinion Letter February 23, 1983
US

Cascade IRA escrow and payroll deductions Unknown

EBSA said Cascade’s escrow account was part of its IRA payroll-deduction program and could remain outside ERISA pension-plan status if the regulatory conditions were met. Depositing withheld pay in…

Advisory Opinion 83-010A Opinion Letter February 9, 1983
US

Affiliate IRA sponsor and employer endorsement Unknown

EBSA said an employer did not endorse an IRA payroll-deduction program solely because the sponsor was its affiliate, if the earlier conditions were met and the affiliate sponsor offered IRA programs…

Advisory Opinion 1983-09A Opinion Letter February 9, 1983
US

Fire extinguisher education and evacuation training

A hospital asked about fire extinguisher and emergency plan training. OSHA said its extinguisher education requirement did not require hands-on practice with controlled fires in the described case.…

1983-01-28 Opinion Letter January 28, 1983
US

Truman Medical Center plan remains nongovernmental Unknown

EBSA declined to change its earlier conclusion that the Truman Medical Center retirement plan was not a governmental plan. It still viewed the center as an independent contractor rather than a…

Advisory Opinion 1983-08A Opinion Letter January 24, 1983
US

Plan pay for a fully paid union representative Unknown

The Department assumed the Cap Makers funds’ administrator received full-time pay as an international union representative, although the requester had not stated whether she was paid full-time. On…

Advisory Opinion 1983-07A Opinion Letter January 24, 1983
US

ESOP majority-securities design and prudence Unknown

EBSA said an ESOP provision requiring more than half its assets in qualifying employer securities did not itself defeat the statutory primary-investment design requirement. Fiduciaries still had to…

Advisory Opinion 1983-06A Opinion Letter January 24, 1983
US

Public employee coverage under state fire brigade standards

An OSHA official reviewed Tennessee’s proposed fire brigade standard. The memorandum said state plans had to apply the federal fire brigade requirements to both private and public employees, and…

1983-01-14 Opinion Letter January 24, 1983
US

Local 919 pension as multiemployer plan Unknown

EBSA said the Local 919 food-industry pension trust had a substantial business purpose because collective bargaining covered employment matters beyond the pension. It found the other regulatory…

Advisory Opinion 1983-05A Opinion Letter January 19, 1983
US

Baytown mutual benefit association welfare plan Unknown

EBSA said the Baytown association’s medical benefits program was an ERISA welfare plan because the association qualified as an employees’ beneficiary association, even though the employer did not…

Advisory Opinion 1983-04A Opinion Letter January 19, 1983
US

Intermittent anchors for suspended window washing platforms Unknown

An OSHA regional administrator asked how an instruction on intermittent building anchors fit the rule for suspended window washing platforms. OSHA said the instruction recognized an equivalent…

1983-01-18 Opinion Letter January 18, 1983
US

Integon payroll-deduction insurance safe harbor Unknown

The Department said Integon’s proposed insurance payroll-deduction program was not an ERISA welfare plan. It saw no indication of a pension plan but limited its opinion to the welfare-plan question.…

Advisory Opinion 1983-03A Opinion Letter January 17, 1983
US

Means of egress rules and the Life Safety Code Unknown

A safety consultant asked whether the Life Safety Code controlled interpretation of OSHA's means of egress rules. OSHA said the cited NFPA edition had no independent force of law, and that its…

1983-01-17 Opinion Letter January 17, 1983
US

Questions on 1982 UCX amendments

ETA answered state questions about implementing 1982 amendments governing unemployment compensation for ex-servicemembers. ETA still lists the letter as continuing.

UIPL No. 13-83 Guidance January 14, 1983
US

IRA premium reimbursements and ERISA Unknown

EBSA said the insurer’s reimbursement to employees of four percent of their IRA premiums, an amount equal to its usual sales commission, would make its payroll-deduction program an ERISA pension…

Advisory Opinion 1983-02A Opinion Letter January 13, 1983
US

IRA fee waivers and employer endorsement Unknown

EBSA could not assure that a brokerage employer’s IRA program stayed outside ERISA when it waived usual enrollment and management fees for employees. The proposed payroll-deduction program failed…

Advisory Opinion 1983-01A Opinion Letter January 13, 1983
US

Guardrail citations during structural floor slab pours Unknown

An OSHA regional administrator asked which construction provision to cite for guardrails during structural floor slab pours. OSHA agreed that section 1926.500(d)(1) applied during the pouring of…

1982-12-29 Opinion Letter December 29, 1982
US

Easco employee health program covered by ERISA Unknown

EBSA said Easco’s employee health program was an ERISA welfare plan both before and after its funding changed. The employer maintained it for employees and beneficiaries, and the insurance method…

Advisory Opinion 1982-68A Opinion Letter December 21, 1982
US

Bank IRA pricing differences and payroll deduction Unknown

EBSA said a bank’s IRA payroll-deduction programs for unrelated employers did not become ERISA pension plans solely because their IRA terms differed from products sold to individuals outside payroll…

Advisory Opinion 1982-67A Opinion Letter December 21, 1982
US

1982 amendments to UCX benefits

ETA explained 1982 statutory changes to eligibility and payment of unemployment compensation for ex-servicemembers. ETA still lists the letter as continuing.

UIPL No. 09-83 Guidance December 17, 1982
US

Inpak pension reporting and alternative compliance Unknown

EBSA said Inpak’s proposed reporting and disclosure steps appeared to meet the applicable ERISA requirements in form for its 1980 plan year. It declined to certify full compliance without reviewing…

Advisory Opinion 1982-66A Opinion Letter December 15, 1982
US

IRA referral fees and broker fiduciary status Unknown

EBSA said a referral fee became unconditional when a new IRA came into existence, even if the bank paid it earlier. It declined to clear several scenarios because a broker’s fiduciary status…

Advisory Opinion 1982-65A Opinion Letter December 14, 1982
US

Thrift-company savings instruments under ERISA Unknown

EBSA treated Fireside Thrift as a bank or similar financial institution under the cited ERISA exemption. Plan investments in its savings instruments could qualify if the remaining conditions,…

Advisory Opinion 1982-64A Opinion Letter December 14, 1982
US

Detroit port authority benefit plans governmental Unknown

EBSA said the Detroit/Wayne County Port Authority was a governmental agency or instrumentality, so its employee benefit plans were governmental plans outside ERISA Title I. Groups formed partly by…

Advisory Opinion 1982-63A Opinion Letter December 9, 1982
US

Affiliate bank trustee and plan investment fund Unknown

EBSA said retaining an affiliated bank as plan trustee did not itself violate the cited self-dealing rules, and service or collective-fund exemptions could apply if their conditions were met.…

Advisory Opinion 1982-62A Opinion Letter December 8, 1982
US

Preventing improper UI payments to undocumented aliens Unknown

ETA gave state agencies procedures for detecting and preventing unemployment benefit payments that federal law barred for certain noncitizens. Current status is unconfirmed.

UIPL No. 06-83 Guidance December 1, 1982
US

Photo-grey safety lenses in changing light Unknown

A senator relayed a company's question about photo-grey safety lenses. OSHA said the lenses were unsuitable for indoor work with changing light, but could be used where light stayed fairly constant…

1982-11-19 Opinion Letter November 19, 1982
US

SEP disclosure method with withdrawal restrictions Unknown

EBSA said employers using Foothill Thrift SEP accounts could use the cited alternative reporting and disclosure method despite certificate withdrawal limits if all conditions were met. Any…

Advisory Opinion 1982-61A Opinion Letter November 17, 1982
US

Fire hose factory tests and annual inspections

A utility asked how OSHA’s fire hose rule applied to factory testing and later maintenance. OSHA said a factory acceptance test with couplings attached satisfied the cited requirement. The rule did…

1982-11-16 Opinion Letter November 16, 1982
US

1982 tax act changes to unemployment programs

ETA explained Tax Equity and Fiscal Responsibility Act changes to extended benefits, state unemployment loans, and federal unemployment taxes. ETA still lists the letter as continuing.

UIPL No. 04-83 Guidance November 15, 1982
US

Ford salaried income security as welfare plan Unknown

EBSA said Ford’s salaried income security program was an ERISA welfare plan and did not appear to be a pension plan because it did not defer pay to termination or provide retirement income on the…

Advisory Opinion 1982-60A Opinion Letter November 12, 1982
US

Chiropractors insurance trust outside ERISA plan status Unknown

EBSA said the chiropractic associations did not themselves maintain an ERISA welfare plan through the health trust because employer members did not control them. An individual employer adopting the…

Advisory Opinion 1982-59A Opinion Letter November 10, 1982
US

Short-period work prospects for extended benefits Unknown

ETA explained that states may interpret the “reasonably short period” for an extended-benefit claimant’s prospects of returning to customary work as longer than four weeks. Current status is unconfirmed.

UIPL No. 01-83 Guidance November 8, 1982
US

Maryland blind-industry pensions governmental Unknown

EBSA said Blind Industries and Services of Maryland was a state agency or instrumentality, making its employee pension plans governmental plans outside ERISA Title I. A state rehabilitation…

Advisory Opinion 1982-58A Opinion Letter November 8, 1982
US

Small-business group trust outside ERISA plan status Unknown

EBSA said the Eastern Small Business Federation trust was not itself a single ERISA welfare plan because participating employer-members did not control the trust, which was controlled by the…

Advisory Opinion 1982-57A Opinion Letter November 2, 1982
US

Wage continuation during sickness outside ERISA Unknown

EBSA said the proposed wage continuation policies paid from each employer’s general assets for illness or injury absences, lasting up to 13 to 39 weeks, were payroll practices outside ERISA…

Advisory Opinion 1982-56A Opinion Letter October 29, 1982
US

Sawdust on workplace floors Unknown

A congressman asked about sawdust used on a workplace floor. OSHA said its walking surface rule required clean, orderly, sanitary floors but did not prohibit sawdust when it created no employee…

1982-10-26 Opinion Letter October 26, 1982
US

Contact lenses during welding

An OSHA region asked whether workers could wear contact lenses while welding. OSHA said contact lenses were acceptable when workers used required eye protection, unless the process produced gas or…

1982-10-22 Opinion Letter October 22, 1982
US

Vanguard affiliate services and self-dealing Unknown

EBSA said a trust company’s appointment of Vanguard Group to provide services would not itself be prohibited self-dealing where the trustee did not use plan-asset authority for its own or Vanguard’s…

Advisory Opinion 1982-55A Opinion Letter October 15, 1982
US

Sisters of Mercy welfare-plan audit exemption denied Unknown

EBSA denied an audit exemption for three Sisters of Mercy welfare plans. The trust was not an employee organization for the cited limited exemption, and the employer maintained the plans; a proposed…

Advisory Opinion 1982-54A Opinion Letter October 13, 1982
US

IRA payroll materials and employer endorsement Unknown

EBSA addressed an insurer’s IRA payroll-deduction program and said employer involvement such as a name or logo on materials would not alone create an ERISA plan if the regulatory conditions were…

Advisory Opinion 82-053A Opinion Letter October 4, 1982

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