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

Asbestos-containing joint compound and surfacing material

A South Carolina safety official asked why OSHA treated asbestos-containing wallboard joint compound differently from surfacing material. OSHA said the standard's Class II work definition and…

1998-05-14 Opinion Letter May 14, 1998
US

Transportation services for welfare-to-work participants Withdrawn

ETA, HHS and DOT told state and local agencies how then-current TANF and Welfare-to-Work funds could support transportation for eligible families moving into jobs. The letter explains funding…

TEGL No. 09-97 Guidance May 8, 1998
US

Brake monitoring and training for mechanical power presses

A requester asked three questions about mechanical power presses. OSHA said a brake monitor was not required under the specified no-hands-in-die conditions, set no fixed training period, and…

1998-05-08 Opinion Letter May 8, 1998
US

HAZWOPER refresher training and documentation

An environmental services employer asked whether an outside trainer had to cover company-specific HAZWOPER content and how annual refresher training should be documented. OSHA said the employer…

1998-05-07 Opinion Letter May 7, 1998
US

Reimbursing combined wage claims through Treasury's unemployment trust fund system Withdrawn

ETA told state unemployment agencies to reimburse other states for combined wage claims through Treasury's online Unemployment Trust Fund system. It gave interim instructions for showing incoming…

UIPL No. 27-98 Guidance May 6, 1998
US

Physician signature on asbestos medical-surveillance opinions

A company asked whether someone working under a licensed physician could sign the written opinion required after an asbestos medical examination. OSHA said the physician had to review and concur in…

1998-05-05-1 Opinion Letter May 5, 1998
US

Blood-derived medicines under the bloodborne pathogens rule

A hospital asked whether employees handling immune globulins, albumin and clotting factors could rely on a supplier's material safety data sheet instead of bloodborne pathogen precautions. OSHA said…

1998-05-05-0 Opinion Letter May 5, 1998
US

Fax access to injury logs and hearing-loss recordability Unknown

An airline asked whether centrally stored injury logs could be faxed promptly to worksites and when hearing-test shifts had to be recorded. OSHA said immediate printed access by fax met the…

1998-05-05 Opinion Letter May 5, 1998
US

OSHA's 1998 position on workplace drug and alcohol hazards Unknown

A safety coordinator asked whether OSHA required a workplace free of alcohol- or drug-impaired machine operators. OSHA said in 1998 it had no specific standard, supported reasonable prevention…

1998-05-02 Opinion Letter May 2, 1998
US

IRS levies on unemployment compensation Unknown

ETA told state unemployment agencies that, although the IRS had authority to levy up to 15 percent of certain unemployment benefits, it had chosen not to use that authority except for child support…

UIPL No. 25-98 Guidance May 1, 1998
US

Two-in/two-out staffing for interior firefighting

A lawyer asked OSHA for examples supporting its two-in/two-out rule for interior firefighting. OSHA said two firefighters inside must remain in contact and at least two outside must monitor and be…

1998-04-29 Opinion Letter April 29, 1998
US

First-instance OSHA penalties and consultation services Unknown

A member of Congress asked why OSHA could penalize a business on its first inspection and how it calculated the amount. OSHA said Congress authorized first-instance penalties and described a case in…

1998-04-27 Opinion Letter April 27, 1998
US

Qualified inspectors for annual bakery oven checks

A baking cooperative asked whether a particular experienced representative could perform members' annual oven inspections. OSHA said it interpreted the rule's manufacturer-representative requirement…

1998-04-24-1 Opinion Letter April 24, 1998
US

Chest freezers and permit-required confined spaces

A trainer asked whether a typical chest freezer with a top lid counted as a permit-required confined space. OSHA said the described shallow freezers did not meet the restricted-entry-or-exit element…

1998-04-24-0 Opinion Letter April 24, 1998
US

Residential construction and slide-guard fall protection Unknown

A construction adviser asked whether house-like buildings used for other purposes could use residential fall-protection alternatives and whether slide guards sufficed. OSHA described its…

1998-04-24 Opinion Letter April 24, 1998
US

Minimum disaster unemployment benefit amounts for April–June 1998 Withdrawn

ETA gave state employment agencies minimum weekly Disaster Unemployment Assistance amounts for major disasters declared from April through June 1998. Its attachment lists each jurisdiction's average…

UIPL No. 22-98 Guidance April 22, 1998
US

Eating and drinking in pharmacy work areas Unknown

A senator asked whether OSHA prohibited eating or drinking anywhere medications were handled in a pharmacy. OSHA said it had no pharmacy-specific ban, but its sanitation rule barred those activities…

1998-04-22 Opinion Letter April 22, 1998
US

Class III asbestos work, training and protective measures

An environmental consultant asked how asbestos rules applied to fastening objects into walls and floors and which materials counted as surfacing material. OSHA said work had to be evaluated case by…

1998-04-21 Opinion Letter April 21, 1998
US

Aerial-lift restraint and fall arrest for electrical work Unknown

A rural electric cooperative asked how fall protection rules applied to workers in aerial lifts. OSHA explained that restraint prevents a lower-level fall, fall arrest requires a harness rather than…

1998-04-20-0 Opinion Letter April 20, 1998
US

Scaffold platform width on concrete formwork walers

A safety consultant asked whether a worker could stand on a narrow waler attached to concrete formwork. OSHA said the photographed waler was a scaffold platform under its scaffold rule, so the…

1998-04-20 Opinion Letter April 20, 1998
US

Year 2000 compliance for JTPA reporting systems Rescinded

ETA asked states to assess, update and test Job Training Partnership Act reporting systems for Year 2000 date problems. It set out state and federal responsibilities, including work with local…

TEGL No. 07-97 Guidance April 17, 1998
US

Incipient-fire response in permit-required confined spaces

A safety consultant asked whether responders could enter a permit-required confined space to extinguish an incipient fire without first obtaining an entry permit. OSHA said the fire-brigade rule…

1998-04-17 Opinion Letter April 17, 1998
US

Sunscreen and clothing for outdoor-worker sun exposure

A requester asked OSHA how it viewed skin-cancer risks for outdoor workers. OSHA said its general PPE rule addressed sun radiation indirectly and pointed to wide-brim hats and long sleeves, with…

1998-04-16 Opinion Letter April 16, 1998
US

Reallotment of JTPA Title III formula funds for program year 1997 Withdrawn

ETA sent state workforce agencies a Federal Register notice reallocating unspent JTPA Title III funds. The notice identifies states whose funds would be recaptured, explains redistribution to…

TEGL No. 06-97 Guidance April 14, 1998
US

Separate injury log for a shared warehouse Unknown

A company asked whether a warehouse shared by two manufacturing sites needed its own injury and illness log, even though no workers were permanently assigned there. OSHA said the warehouse was a…

1998-04-14-0 Opinion Letter April 14, 1998
US

Separate injury logs, splints and heart-attack recordability Unknown

A lawyer posed six injury-recording scenarios involving nearby worksites, a separate printing site, splints and a heart attack at work. OSHA said adjacent related facilities could share a log while…

1998-04-14 Opinion Letter April 14, 1998
US

Retail food items under the hazard communication rule

A requester asked whether ordinary grocery foods needed material safety data sheets. OSHA said food and alcoholic beverages sold, used or prepared in retail establishments were exempt from the cited…

1998-04-07-0 Opinion Letter April 7, 1998
US

Latex gloves in food preparation

A congressional staff member asked whether OSHA required food-service workers to wear latex gloves. OSHA said it had no such rule; food handling glove requirements came from FDA's Food Code. The…

1998-04-07 Opinion Letter April 7, 1998
US

Prompt access to workplace toilets and citation review

OSHA told regional offices that employers must make toilet facilities available when workers need them and may not impose unreasonable delays. It said access restrictions should be evaluated case by…

1998-04-06-0 Guidance April 6, 1998
US

Back belts, lifting hazards and worker safety complaints

A worker proposed a back-belt safety campaign and described adverse reactions to safety complaints. OSHA said it preferred engineering and work-design controls for lifting hazards and had not found…

1998-04-06 Opinion Letter April 6, 1998
US

Computerized OSHA 101 supplementary injury records Unknown

An employer group asked whether supplementary OSHA 101 injury forms could be kept in a computer system or at a central office. OSHA said yes under three conditions covering timely entry, complete…

1998-04-03 Opinion Letter April 3, 1998
US

Electronic brakes on bakery equipment

A safety consultant asked whether an electronic brake for a bun slicer could satisfy OSHA's older bakery-equipment rule. OSHA said employers remained responsible for compliance but that a newer…

1998-04-02 Opinion Letter April 2, 1998
US

1997 unemployment insurance benefit accuracy data release Withdrawn

ETA told state unemployment agencies how to prepare and review 1997 Benefit Accuracy Measurement data, including the April 30, 1998 database cutoff and formats for the annual and supplemental…

UIPL No. 20-98 Guidance April 1, 1998
US

Professional athletes' between seasons unemployment compensation

ETA explained its view that states must deny unemployment compensation between sports seasons when substantially all base period services were athletic and there is reasonable assurance of athletic…

UIPL No. 18-98 Guidance March 30, 1998
US

Final 1998 Wagner-Peyser labor exchange allotments Withdrawn

ETA announced each state's final program year 1998 basic labor exchange allotment under the Wagner-Peyser Act. The letter explains the statutory formula, a 3 percent reserve used to hold certain…

TEGL No. 05-97 Guidance March 30, 1998
US

Fire-retardant clothing and workplace PPE assessments

A safety engineer asked whether OSHA generally mandated fire-retardant clothing outside fire brigades and electrical distribution, and how to evaluate it. OSHA said no broad directive applied, but…

1998-03-27-0 Opinion Letter March 27, 1998
US

OSHA's 1998 silicosis emphasis program Unknown

A member of Congress asked about OSHA's silicosis Special Emphasis Program. OSHA said the program began in 1996, combined outreach and enforcement, and targeted industries with silica hazards. The…

1998-03-27 Opinion Letter March 27, 1998
US

Protective clothing for formaldehyde exposure in embalming

A requester asked how OSHA's formaldehyde standard affected funeral-home embalming. OSHA said the standard applied and described full-body protection conditions: air concentrations above 100 ppm or…

1998-03-25 Opinion Letter March 25, 1998
US

Enforcement of the OSHA workplace poster requirement Unknown

A compliance specialist asked how often OSHA cited employers for failing to post its workplace notice. OSHA reported citation counts for fiscal years 1996 and 1997 and said inspectors then gave…

1998-03-20 Opinion Letter March 20, 1998
US

Scaffold rules for shoring frames used as work platforms Unknown

A carpenters' training group asked whether shoring frames supporting temporary decks or work platforms were covered by scaffold rules. OSHA said both described uses created scaffolds, including…

1998-03-17 Opinion Letter March 17, 1998
US

Roll-over protection and hazardous-energy control in construction Unknown

A labor safety fund asked OSHA to address roller-compactor rollovers and uncontrolled energy during construction maintenance. OSHA said rollovers and unexpected energization were recognized hazards…

1998-03-16-1 Opinion Letter March 16, 1998
US

Rollover protection for compactors and skid-steer equipment

A safety consultant asked whether a pneumatic compactor needed rollover structures, seat belts or other safeguards. OSHA said it had no equipment-specific rule then, but regarded rollovers as a…

1998-03-16-0 Opinion Letter March 16, 1998
US

Identifying the worker who applies a lockout device Unknown

A manufacturer asked whether lockout devices needed permanent engraved identification or could carry an attached name tag. OSHA said the identity requirement was performance-based and either…

1998-03-16 Opinion Letter March 16, 1998
US

OSHA's formaldehyde exposure-limit rulemaking

A physician disputed OSHA's formaldehyde standard. OSHA responded with the rulemaking history, explaining that it reduced the eight-hour permissible exposure limit to 0.75 ppm after a court…

1998-03-13-0 Opinion Letter March 13, 1998
US

1998 citation policy for OSHA injury survey nonresponders Unknown

OSHA set an enforcement policy for employers that did not return injury and illness data in its 1998 collection. It said first-time survey participants would not be cited merely for nonresponse,…

1998-03-13 Guidance March 13, 1998
US

OSHA inspections at tribal workplaces

A member of Congress asked whether OSHA could inspect a casino operated by a tribal enterprise after an employee complaint. OSHA said the OSH Act generally applied to workplaces on tribal land and…

1998-03-12-1 Opinion Letter March 12, 1998
US

Safety net stanchion compliance and proposed general industry rules Unknown

A requester asked OSHA to approve a patented safety net stanchion. OSHA said it would assess a complete fall protection system during an inspection, rather than approve this component by letter. It…

1998-03-12-0 Opinion Letter March 12, 1998
US

Welder electrical training and transmission and distribution definitions

An employer asked whether welders whose equipment generally operates below 50 volts could be exempt from electrical safety training. OSHA answered no, citing the welding standards' training…

1998-03-12 Opinion Letter March 12, 1998
US

Calendar year 1998 summer youth employment program guidance and allotments Withdrawn

ETA instructed states on running the 1998 summer youth jobs and training program, including education, work experience, funding transfers, and job safety. It said the lower federal youth opportunity…

TEGL No. 04-97 Guidance March 9, 1998
US

JTPA allotments and Wagner-Peyser planning estimates for 1998 Withdrawn

ETA provided states with 1998 JTPA training allotments and preliminary Wagner-Peyser employment service planning estimates. It explained the data and formulas used, when funding notices would issue,…

TEGL No. 03-97 Guidance March 9, 1998
US

Roth IRAs within prohibited transaction exemption 97-11 Unknown

A requester asked whether Roth IRAs counted as IRAs under prohibited transaction exemption 97-11. EBSA said a Roth IRA meeting the statutory individual retirement plan definition was within the…

Advisory Opinion 1998-03A Opinion Letter March 6, 1998
US

Medical group incentive plan as bonus or pension plan Unknown

A medical group asked whether its key employee incentives were an excluded bonus program or a pension plan, and whether any pension plan was a top-hat plan. EBSA said the terms did not establish a…

Advisory Opinion 1998-02A Opinion Letter March 6, 1998
US

Waist straps in full body fall arrest harnesses

A manufacturer asked whether a full body harness could include a waist strap and how to address misuse. OSHA said a waist or chest strap is permitted when the harness distributes fall forces as…

1998-03-06 Opinion Letter March 6, 1998
US

PSM pressure vessels built under earlier ASME editions

An engineer asked how OSHA's process safety management rule applies to pressure vessels built under earlier ASME code editions. OSHA said employers must document differences from current codes and…

1998-03-05-0 Opinion Letter March 5, 1998
US

Federal and state plan injury recordkeeping authority Unknown

An employer asked who interprets OSHA injury recordkeeping rules, whether state plans use the same definitions, and how to classify an employee's restricted work after a 1997 injury. OSHA identified…

1998-03-05 Opinion Letter March 5, 1998
US

Logging standard and commercial tree trimming Withdrawn

OSHA told an arborist association that the logging operations standard applied to commercial tree trimming and cutting. OSHA expressly withdrew this response on June 22, 1998, while it reconsidered…

1998-03-04-0 Opinion Letter March 4, 1998
US

Trailer restraint and chocking at loading docks Unknown

A physician asked about workers injured when trailers move away from loading docks during forklift operations. OSHA discussed trailer restraint, chocking and safe work practices. OSHA later struck…

1998-03-04 Opinion Letter March 4, 1998
US

FMLA leave to attend a parent's care conference

WHD considered whether an employee could use FMLA leave to attend a care conference about her mother's serious health condition. It said such a meeting with health care providers is part of…

FMLA-94 Opinion Letter February 27, 1998
US

Radiation exposure records for NRC licensee contractors

A contractor asked whether it had to duplicate radiation exposure records kept by an NRC licensee. OSHA said the licensee's compliance with the cited NRC monitoring and recordkeeping rules satisfied…

1998-02-23 Opinion Letter February 23, 1998
US

Interrupted hepatitis B vaccine series under the bloodborne pathogens rule

A nursing agency asked whether an employee who missed a scheduled hepatitis B vaccine dose had to restart the entire series. OSHA said the series should continue according to then-current public…

1998-02-19 Opinion Letter February 19, 1998

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