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

Temporary lighting strings with non-heavy-duty cord

An electrical maker asked about temporary construction lighting strings that lacked heavy-duty cord. OSHA said listed manufactured strings installed under their listing instructions and kept safe…

1981-09-16 Opinion Letter September 16, 1981
US

Salary continuance as a payroll practice Unknown

The Labor Department said The Continental Corporation’s salary continuance for medical absences, paid from employer general assets and capped at normal pay, was a payroll practice outside ERISA…

Opinion 81-71A Opinion Letter September 11, 1981
US

General safety requirements for hand tools

A requester asked about OSHA requirements for hand tools. OSHA said it did not prescribe general tool dimensions, but employers had to keep tools and equipment in a safe condition. It also…

1981-09-11 Opinion Letter September 11, 1981
US

Illinois general interest-rate law and plan loans Unknown

The Labor Department said ERISA preempted Illinois’s general interest-rate ceiling to the extent the statute applied to loans made by covered employee benefit plans. It found the law was a broad…

Opinion 81-70A Opinion Letter September 9, 1981
US

Extended-benefit work-test interpretation changes

ETA revised and clarified its interpretation of the federal extended-benefit work test in the 1980 Omnibus Reconciliation Act. ETA still lists the letter as continuing.

UIPL No. 14-81, Change 2 Guidance September 8, 1981
US

Dock securing under powered industrial truck rules

A dock equipment company asked about truck and trailer restraint during loading. OSHA said the powered industrial truck rule covered several truck types, and securing a trailer to the dock could be…

1981-09-03 Opinion Letter September 3, 1981
US

Meals and lodging as FUTA wages after Rowan Unknown

ETA explained the Supreme Court’s Rowan decision on whether employer-provided meals and lodging count as wages under federal unemployment tax law. Current status is unconfirmed.

UIPL No. 39-81 Guidance September 2, 1981
US

Blasting mats and drilling near charged holes

An OSHA region asked about construction blasting distances. OSHA said equipment such as a backhoe placing blasting mats was not covered by the cited 50-foot equipment restriction. It distinguished…

1981-08-26 Opinion Letter August 26, 1981
US

Competent persons for construction crane inspections Unknown

A construction manager asked whether employees inspecting cranes needed an ANSI Level II rating. OSHA said its rules required competent persons for pre-use and annual inspections, but did not…

1981-08-18 Opinion Letter August 18, 1981
US

Third-class mailing of pension plan disclosures Unknown

The Labor Department said the Teamsters pension fund could mail required disclosures by second or third class without guaranteed return and forwarding postage if it requested address corrections and…

Opinion 81-68A Opinion Letter August 13, 1981
US

ESOP money purchase plan and employer securities Unknown

The Labor Department said a qualified money purchase plan forming part of an employee stock ownership plan would be an eligible individual account plan for the cited ERISA employer-securities limit.…

Opinion 81-67A Opinion Letter August 10, 1981
US

Hospital pension loan to a medical center Unknown

The Labor Department said Lakeland Medical Center was not a party in interest to the hospital’s pension plan on the facts supplied. It declined to decide whether a proposed plan loan to the center…

Opinion 81-66A Opinion Letter August 10, 1981
US

When fire detection and employee alarm rules apply

An insurer asked when OSHA’s fire detection and employee alarm rules applied. OSHA said the cited provisions applied to systems installed to meet particular OSHA standards, and gave examples of…

1981-08-07 Opinion Letter August 7, 1981
US

Teamsters pension escrow account outside ERISA Unknown

The Labor Department said an escrow account established to hold employer contributions for possible entry into a Teamsters pension plan was not itself an ERISA welfare or pension plan. It did not…

Opinion 81-65A Opinion Letter August 3, 1981
US

Employer contribution of real estate option to pension plan Unknown

The Labor Department said an employer’s contribution of a condominium purchase option to satisfy its defined-benefit plan funding obligation was a prohibited sale or exchange with a party in…

A.O. 81-69 Opinion Letter July 28, 1981
US

Steel band guardrails at concrete slab edges Unknown

A concrete contractor asked whether steel bands could protect workers at building slab edges. OSHA said ordinary bands posed an edge hazard, but a flagged, edge-protected, strong, and regularly…

1981-07-28 Opinion Letter July 28, 1981
US

Transit plan reporting after public acquisition Unknown

The Labor Department said a midyear sale of two transit companies to a state entity did not alone accelerate their plans’ reporting deadlines. Former administrative committee members generally were…

Opinion 81-64A Opinion Letter July 24, 1981
US

Holiday Inn health plans and Florida insurance review Unknown

The Labor Department said seven individually established Holiday Inn benefit plans were ERISA welfare plans and could not be deemed insurers under Florida insurance law. It could not decide whether…

Opinion 81-63A Opinion Letter July 24, 1981
US

Temporary worker housing beyond migrant agriculture

An OSHA region asked whether the temporary labor camp rule was limited to migrant farmworkers. OSHA said the rule applied to employer-provided temporary job housing for workers away from a permanent…

1981-07-23-0 Opinion Letter July 23, 1981
US

Legal-services plans, state insurance law, and pooled assets Unknown

The Labor Department said providing services to ERISA plans did not by itself preempt state regulation of the service provider; the particular law and insurance exception mattered. Separate employer…

Opinion 81-62A Opinion Letter July 21, 1981
US

Credit union prepaid legal-services plan Unknown

The Labor Department treated the N&W Employees Credit Union as an employee organization and its prepaid legal-services program as an ERISA welfare plan. The provider’s participation alone did not…

Opinion 81-61A Opinion Letter July 21, 1981
US

Phoenix Steel annuity plan after final insurance payment Unknown

The Labor Department said Phoenix Steel’s old pension plan would be outside ERISA if, after the Bank waived its contract rights, annuitants could choose on their own to enforce benefits against the…

Opinion 81-60A Opinion Letter July 21, 1981
US

Kimberly-Clark employee fund and audit requirement Unknown

The Labor Department said the Munising Mill employees’ benefit fund was an ERISA welfare plan and ordinarily needed an independent accountant’s audit. It was considering a specific exemption,…

Opinion 81-59A Opinion Letter July 15, 1981
US

Air-supplied welding helmets and breathing-air quality

A helmet maker asked whether a cooling-air welding helmet could be used wherever standard helmets were allowed. OSHA said the supplied air had to meet Grade D breathing-air quality and the helmet…

1981-07-14 Opinion Letter July 14, 1981
US

Milk vendors pension plan and ERISA coverage Unknown

The Labor Department said a milk-vendor pension plan did not appear covered by ERISA Title I on the limited material supplied because the vendors did not appear to be employees of the milk…

Opinion No. 81-88A Opinion Letter July 9, 1981
US

Canadian mine pension plan outside ERISA Unknown

Based on the requester's account that the covered employees were Canadian residents and not U.S. citizens, and that the relevant operations were in Canada, the Labor Department said the Wabush Mines…

Opinion 81-58A Opinion Letter July 2, 1981
US

Rooftop fall protection for powered platform access Unknown

An engineer asked about protection on roofs where workers access powered platforms. OSHA said it would accept a three-foot guardrail in the described locations and an adequately anchored permanent…

1981-07-01 Opinion Letter July 1, 1981
US

Audible warning horns on construction equipment

A contractor asked whether older construction equipment was exempt from horn requirements. OSHA said motor vehicles and bidirectional equipment such as bulldozers and loaders needed operable audible…

1981-06-30 Opinion Letter June 30, 1981
US

Rollover IRA loan to owner’s company Unknown

The Labor Department said an IRA established from a former employer’s plan distribution met two regulatory conditions for being outside ERISA pension-plan status. A loan from the IRA to the owner’s…

Opinion 81-57A Opinion Letter June 29, 1981
US

Firefighters association group life insurance Unknown

The Labor Department treated a Nashville-area government firefighters association as an employee organization under ERISA. It declined to decide whether the association endorsed a voluntary group…

Opinion 81-56 Opinion Letter June 29, 1981
US

Deferred vacation benefits as welfare plan Unknown

The Labor Department said American Motors’ proposed deferred vacation benefit arrangement appeared to satisfy its severance-pay exclusion from ERISA pension-plan status, assuming reasonable…

Opinion 81-55A Opinion Letter June 26, 1981
US

Manual fire alarms and employee emergency plans

An employer asked about supervised manual fire alarms. OSHA said there was no general requirement to install a manual fire alarm, but a system installed for an emergency plan had to meet applicable…

1981-06-26 Opinion Letter June 26, 1981
US

Height, bracing, and rails on mobile scaffold towers Unknown

A scaffold manufacturer asked how construction rules applied to a mobile tower. OSHA said the photographed unit should be treated as one tower and meet the then-current height-to-base ratio,…

1981-06-25 Opinion Letter June 25, 1981
US

Low pitched roof perimeter rule and built-up roofing Unknown

An OSHA regional office asked when its low-pitched roof perimeter rule applied. OSHA said the then-current rule addressed built-up roofing work, while other roofing tasks could fall under other fall…

1981-06-24-0 Opinion Letter June 24, 1981
US

Scholarship fund participants and reporting Unknown

The Labor Department said individuals meeting the Arthur J. Faggion Scholarship Fund's eligibility criteria were participants, and their eligible children were beneficiaries. Those criteria included…

Opinion 81-54A Opinion Letter June 22, 1981
US

Electrical grounding, clearances, and grain dust classifications

An OSHA region asked six questions about the revised general-industry electrical rules. OSHA explained when grounding-type receptacles and terminals were required, how limited exposed live parts and…

1981-06-22-0 Opinion Letter June 22, 1981
US

Alaska public employees legal plan status Unknown

The Labor Department said the Alaska Public Employees Legal Fund was a governmental plan outside ERISA Title I, despite its collective bargaining origin and joint administration. The conclusion…

Opinion 81-53A Opinion Letter June 18, 1981
US

Thomas decision on religious voluntary quits Unknown

ETA explained the Supreme Court’s Thomas decision and its implications for unemployment benefits after a worker quits for religious reasons. Current status is unconfirmed.

UIPL No. 27-81 Guidance June 16, 1981
US

Gratuitous death benefit from pension assets Unknown

The Labor Department said paying a fund manager’s widow a gratuitous death benefit from pension assets would violate ERISA’s exclusive-purpose duties because she was not a plan beneficiary and the…

Opinion 81-52A Opinion Letter June 15, 1981
US

Treadle-activated security locks on exit doors

A company asked whether a security door opened by a treadle pad met the exit route rule. OSHA said the system appeared acceptable if the pad released the door and exit remained possible during power…

1981-06-10 Opinion Letter June 10, 1981
US

Petroleum landmen association insurance programs Unknown

The Labor Department said insurance programs offered by the American Association of Petroleum Landmen were not themselves ERISA welfare plans because the association was neither an employee…

Opinion 81-51A Opinion Letter June 9, 1981
US

Arbitrator fiduciary status and indemnification Unknown

The Labor Department said an arbitrator deciding plan benefit claims could be an ERISA fiduciary, but to the extent the described arbitration concerned only plan design in collective bargaining, it…

Opinion 81-50A Opinion Letter June 4, 1981
US

Training trust as ERISA welfare plan Unknown

The Labor Department said a collectively bargained training trust was an ERISA welfare plan, even though it funded other entities to conduct training. Eligible workers were participants, and the…

Opinion 81-49A Opinion Letter May 28, 1981
US

Longshore job-security funding program Unknown

The Labor Department said a collectively bargained program that collected carrier assessments to cover shortfalls in local longshore benefit plans was not itself an ERISA benefit plan because…

Opinion 81-48A Opinion Letter May 28, 1981
US

Iowa bankers benefit-plan reporting Unknown

The Labor Department could not determine whether the Iowa Bankers Benefit Plan was a single ERISA plan without more facts about the sponsoring bank group. If member banks had separate plans, each…

Opinion 81-47A Opinion Letter May 28, 1981
US

Employer stock contribution and repurchase Unknown

The Labor Department found a company profit-sharing plan was an eligible individual account plan and that its employer stock was qualifying securities. A proposed company repurchase could meet an…

Opinion 81-46A Opinion Letter May 27, 1981
US

ANSI press brake standard as guarding guidance Unknown

An ANSI committee member asked how OSHA used its press brake standard. OSHA said the general machine guarding rule governed mechanical power press brakes and that it used ANSI B11.3 and a later…

1981-05-26 Opinion Letter May 26, 1981
US

Retention and access to accident-related medical X-rays

An OSHA regional memo circulated an April 24 interpretation about medical X-rays. It said accident-only bone films could be excluded from long-term retention under stated conditions, while their…

1981-05-14 Opinion Letter May 14, 1981
US

Medical records held by outside healthcare contractors

A company asked whether its duties under the medical records access rule extended to physical examinations and treatment by outside providers. OSHA said they did: employers remained responsible for…

1981-05-12 Opinion Letter May 12, 1981
US

Crane operator physical qualification requirements Unknown

A union asked whether physical qualification provisions in ANSI crane and derrick standards referenced by OSHA's construction rule applied to equipment operators. OSHA said those incorporated…

1981-05-08 Opinion Letter May 8, 1981
US

Hospital plan fiduciaries serving on insurer board Unknown

The Labor Department said a hospital plan fiduciary’s service on a Blue Cross board was not itself a prohibited conflict under the cited ERISA provision. If the insurer’s interests were adverse to…

Opinion 81-45A Opinion Letter May 5, 1981
US

YWCA savings plan and New York insurance law Unknown

The Labor Department classified a YWCA employees’ savings plan as an ERISA pension plan. Because it was covered and no exclusion appeared to apply, ERISA preempted New York Insurance Law section 200…

Opinion 81-44A Opinion Letter May 4, 1981
US

Life-insurance program and small-plan reporting relief Unknown

The Labor Department said the described Equitable insurance arrangement satisfied paragraph (b)(2)(ii) of the small-plan reporting rule. It did not determine whether the plans satisfied every…

Opinion 81-43A Opinion Letter April 28, 1981
US

Retention of accident-related employee X-rays

A medical clinic asked about preserving worker medical records. OSHA said employees exposed to toxic substances or harmful physical agents generally had medical records retained for employment plus…

1981-04-24 Opinion Letter April 24, 1981
US

Steel truss work and perimeter fall protection Unknown

A lawyer sought a variance for perimeter netting during steel truss work. OSHA discussed static lines, ladder access, and the limited circumstances in which initial steel connectors might work…

1981-04-17 Opinion Letter April 17, 1981
US

Early redemption penalty on bank plan deposits Unknown

The Labor Department said an ERISA exemption could cover bank-rule penalties when a bank-sponsored plan redeemed its certificates of deposit early. The exemption did not excuse fiduciary prudence,…

Opinion 81-42A Opinion Letter April 6, 1981
US

Sun retirement plan employer-security limits Unknown

The Labor Department treated Sun’s retirement arrangement as one plan for ERISA employer-securities limits, rather than separate plans for each participating corporate employer. It relied on the…

Opinion 81-41A Opinion Letter April 6, 1981
US

California dental program outside ERISA plan status Unknown

The Labor Department said Peoples Dental and its dental program were not ERISA welfare plans because the sponsoring association was neither an employee organization nor an employer and no employer…

Opinion 81-40A Opinion Letter April 6, 1981
US

Retiree travel passes outside ERISA coverage Unknown

The Labor Department said Eastern Airlines’ reduced-rate travel program for retirees was not an ERISA welfare plan because travel discounts were not listed benefits, and did not appear to be a…

Opinion 81-39A Opinion Letter April 6, 1981
US

Guarding of nonwoven abrasive wheels

An OSHA office asked for testing of varied nonwoven abrasive wheels before issuing final product-wide guidance. Its preliminary analysis said the abrasive wheel guard rule could apply when a…

1981-04-03 Opinion Letter April 3, 1981

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