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

SCBA use by incipient-stage fire brigades

OSHA allowed the described incipient-stage fire brigade to use self-contained breathing apparatus because of possible toxic combustion products, provided members stayed within incipient-fire duties.…

1996-07-18-1 Opinion Letter July 18, 1996
US

Prescription medication and older injury-log medical treatment Unknown

Under the older recordkeeping guidelines, OSHA viewed one dose of local anesthetic and one dose to treat or prevent infection as two prescription doses, making the case medical treatment rather than…

1996-07-18-0 Opinion Letter July 18, 1996
US

Prison labor and the OSH Act employer definition Unknown

OSHA forwarded a solicitor’s analysis of whether PRIDE, which managed Florida prison work programs, qualified as an excluded state instrumentality under the OSH Act. The opinion concluded a court…

1996-07-18 Opinion Letter July 18, 1996
US

Pretax premium mechanism within group health plan Unknown

An employer asked whether a program allowing employees to pay group health premiums pretax was its own ERISA welfare plan. For the program as currently structured, EBSA said the tax-favored payment…

Advisory Opinion 1996-12A Opinion Letter July 17, 1996
US

NFPA 101 as an interpretive reference for means of egress Unknown

OSHA clarified that a prior statement about NFPA 101 lacking force of law did not bar the agency from using consensus standards as reference sources. The memo includes the 1983 letter it corrected…

1996-07-16-0 Interpretive Notice July 16, 1996
US

Older injury-log, hearing protection, and illness questions Unknown

Under the former recordkeeping rules, OSHA discussed when work-related soreness with restricted duty was recordable, when back symptoms formed a new case, and classification of lice or scabies…

1996-07-16 Opinion Letter July 16, 1996
US

Power roof cutters and asbestos roofing supervisor training Unknown

OSHA said use of a power roof cutter separates built-up roofing into pieces, but pieces can remain intact if the material stays bound in its matrix. It said the described operation required five-day…

1996-07-15-1 Opinion Letter July 15, 1996
US

Electronic safety data access and distributor duties under hazard communication

OSHA allowed electronic MSDS access if employees could obtain information immediately and a backup covered likely outages. It said compressed medical gases were outside the cited solid-drug…

1996-07-15-0 Opinion Letter July 15, 1996
US

Minimum weekly disaster unemployment assistance for July–September 1996 disasters Withdrawn

ETA gave state agencies a table of minimum weekly Disaster Unemployment Assistance amounts for major disasters declared from July 1 through September 30, 1996. It explained that the usual minimum…

UIPL No. 28-96 Guidance July 12, 1996
US

Mercy psychiatric hospital retirement plan as church plan Unknown

A Mercy psychiatric hospital asked whether its employee retirement plan was a church plan excluded from ERISA Title I. EBSA agreed with an IRS private ruling to the extent the hospital and plan were…

Advisory Opinion 1996-11A Opinion Letter July 12, 1996
CA

Meal-period compensation for on-premises health care workers after the 1993 hours-worked change

A member of the public asked DLSE whether a hospital must pay a respiratory therapist for meal periods spent on the premises without being allowed to leave. DLSE explained that under Bono…

1996.07.12 Opinion Letter July 12, 1996
US

Floor openings and stair riser tolerances under older OSHA guidance Unknown

In this historical letter, OSHA cited a proposed provision on guarding certain small equipment openings with a toeboard and pointed to its de minimis policy for minor stair deviations without an…

1996-07-12-0 Opinion Letter July 12, 1996
US

Process operators taking limited action during HAZWOPER emergencies Unknown

OSHA described limited process-operator action during a HAZWOPER emergency if the incident command structure was notified, operators had training and PPE, used the buddy system, and the emergency…

1996-07-11 Opinion Letter July 11, 1996
US

Lutheran home care health and annuity plans Unknown

A Lutheran home care organization asked whether its group health and tax-sheltered annuity plans were church plans. EBSA agreed with an IRS private ruling if the organization and plans were…

Advisory Opinion 1996-10A Opinion Letter July 10, 1996
CA

Overtime exemption for two-axle trucks: scope of the DOT/CHP/PUC hours-of-service carve-out

An attorney representing a portable-toilet waste-hauling company asked whether its two-axle tank-truck drivers were exempt from overtime under IWC Order 9-90's carve-out for drivers whose hours are…

1996.07.10 Opinion Letter July 10, 1996
US

Transfer of employer unemployment experience

ETA interpreted how state unemployment tax systems may transfer an employer’s experience when a business or part of one changes ownership. ETA still lists the letter as continuing.

UIPL No. 29-83, Change 3 Guidance July 9, 1996
US

Christian Brothers employee pension as church plan Unknown

A Christian Brothers plan asked whether it was a church plan. EBSA agreed with an earlier IRS private ruling to the extent the plan continued to be structured and operated as the ruling described.…

Advisory Opinion 1996-09A Opinion Letter July 8, 1996
US

Bakery oven disconnect accessibility in retail stores Unknown

OSHA said the bakery equipment rule applied to retail grocery bakeries. Emergency disconnects had to be quickly and safely reachable, clearly marked if in a panel, and supported by employee…

1996-07-03 Opinion Letter July 3, 1996
US

Bulk sampling to rebut presumed asbestos material

OSHA said the cited asbestos construction and shipyard rules did not distinguish friable and nonfriable materials for bulk sampling. It set out the EPA protocol: three, five, or seven samples for…

1996-06-28-0 Opinion Letter June 28, 1996
US

Disinfectants for HBV and HIV on work surfaces

OSHA accepted two named disinfectants for solid, nonporous, precleaned surfaces if HBV and HIV were the only bloodborne pathogens of concern and EPA-approved concentrations were used. It said other…

1996-06-28 Opinion Letter June 28, 1996
US

Employer stock definition for ESOP purchase exemption Unknown

An employer asked which stock definition applied when an ESOP bought shares from disqualified persons under Code section 4975(d)(13). EBSA said that exemption incorporates ERISA section 408(e) and…

Advisory Opinion 1996-08A Opinion Letter June 26, 1996
US

Bracing masonry walls over eight feet

OSHA said the bracing rule covers masonry walls over eight feet tall unless otherwise adequately supported, with or without rebar. Employers must account for expected forces such as wind and…

1996-06-25 Opinion Letter June 25, 1996
US

Silica special emphasis outreach materials Unknown

OSHA described information cards for construction and general industry, an updated silicosis slide presentation, and training for agency and state consultation staff as part of its silica outreach…

1996-06-21 Opinion Letter June 21, 1996
US

Lockout and tagout procedures, training, and inspections Unknown

OSHA addressed common energy-control procedures, training for every procedure an authorized worker may use, retraining after relevant changes, and annual inspections of each procedure. Its response…

1996-06-20 Opinion Letter June 20, 1996
US

When earned vacation can replace unpaid FMLA leave

WHD considered vacation earned in one year but unavailable for use until the next under a collective bargaining agreement. It said accrued paid leave can replace unpaid FMLA leave only when the…

FMLA-81 Opinion Letter June 18, 1996
US

Proposed injury-log exemptions for small employers and restaurants Unknown

OSHA described a 1996 proposal to exempt employers with no more than 19 employees, revise industry coverage, and bring more restaurant establishments into the logging system. Those were proposed…

1996-06-18 Opinion Letter June 18, 1996
US

Workers compensation decisions and older OSHA injury logs Unknown

OSHA explained that state workers compensation criteria and OSHA recordkeeping criteria differed; a compensation decision did not determine whether a case belonged on the OSHA log. It described work…

1996-06-17-1 Opinion Letter June 17, 1996
US

Illuminating Engineering Society lighting guidance

OSHA identified an IES-assisted industrial lighting consensus standard referenced in general-industry and construction rules. It said employers could use a newer national consensus revision if doing…

1996-06-17-0 Opinion Letter June 17, 1996
US

Preliminary TSCA health studies on material safety data sheets

OSHA said TSCA Section 8(e) reporting and hazard-communication disclosure were separate duties. A statistically significant positive study conducted under established scientific principles could…

1996-06-17 Opinion Letter June 17, 1996
US

Isocyanate respirator approval in auto body spray painting Unknown

OSHA said a proposed charcoal-filter respirator needed NIOSH certification and it could not accept foreign approval alone absent an agreement. It discussed exposure monitoring and when respirators…

1996-06-13 Opinion Letter June 13, 1996
US

Volunteer rescue squads and state-plan OSHA coverage

OSHA said federal occupational safety law excluded state and local public employees, while approved state plans covered public workers. Whether an Iowa volunteer rescue or ambulance squad fell…

1996-06-11 Opinion Letter June 11, 1996
US

Small Business Regulatory Enforcement Fairness Act implementation memo Unknown

A Labor Department solicitor reviewed how the 1996 Small Business Regulatory Enforcement Fairness Act affected OSHA, including compliance guides, small-entity advice, enforcement oversight,…

1996-06-10 Interpretive Notice June 10, 1996
US

Draft workplace violence guidance for late-night retail Unknown

OSHA said it had consulted stakeholders on draft violence-prevention guidance for late-night retailers and that the guidance was educational. The guidelines themselves would not lead to General Duty…

1996-06-06-0 Opinion Letter June 6, 1996
US

Draft retail violence guidelines and enforcement concerns Unknown

OSHA told a member of Congress that draft late-night retail violence guidance was for technical assistance and would not itself trigger General Duty Clause citations. It described stakeholder…

1996-06-06 Opinion Letter June 6, 1996
US

Boy Scouts injury-log exemption under former rules Unknown

Under the former SIC-based injury-log system, OSHA said the Boy Scouts and its camps were regularly exempt from keeping logs, subject to other OSHA duties and a survey-selection exception.…

1996-06-04-4 Opinion Letter June 4, 1996
US

Temporary worker injury logs under former OSHA rules Unknown

Under the former injury-log rules, OSHA said the host firm recorded temporary workers’ cases when it supervised their daily work, including methods and processes. It discussed avoiding double…

1996-06-04-3 Opinion Letter June 4, 1996
US

Off-premises work injury and joint dislocation logging Unknown

OSHA said an off-premises injury could be work-related when the worker was performing company duties or present as a condition of employment. A joint dislocation impairing normal use was nonminor…

1996-06-04-2 Opinion Letter June 4, 1996
US

Business travel injury and location of injury log entry Unknown

OSHA treated the public building entrance as off the employer’s premises, but found the injury work-related because the employee was traveling on company business. Under its former system, it…

1996-06-04-1 Opinion Letter June 4, 1996
US

Casts, splints, and wraps under older medical treatment rules Unknown

Under its former recordkeeping rules, OSHA classified casts, splints, and other devices immobilizing a body part as medical treatment. Wraps, wristlets, and elastic bandages that did not constrain…

1996-06-04-0 Opinion Letter June 4, 1996
US

First aid and tagout in electric power work

OSHA said field crews needed at least two trained first-aid and CPR employees, with rescue equipment and demonstrated proficiency considered in assessing access to care. During testing, only tagout…

1996-06-04 Opinion Letter June 4, 1996
US

Conditions for disclosing unemployment wage records to private entities Withdrawn

ETA said a state unemployment agency could share employment and wage records with a private credit service when state law allowed it and a written agreement met specific conditions. The individual…

UIPL No. 23-96 Guidance May 31, 1996
CA

Wages due at temporary layoff: a return date must fall within the pay period

An industry trade association asked DLSE whether contractual recall rights (whether from a collective bargaining agreement or an employee handbook) mean a "temporary layoff" is not a termination…

1996.05.30 Opinion Letter May 30, 1996
US

Roofing supplier fall protection and roof restraints Unknown

OSHA cited a February 1995 interpretation under which supplier workers delivering materials to residential or similar roofs need not be tied off. It also accepted roof restraints with anchorage and…

1996-05-30 Opinion Letter May 30, 1996
US

Awareness barriers and locked gates around moving machinery Unknown

OSHA said a warning chain generally did not prevent contact with moving machine parts. A locked gate could substitute for individual guards if employees could enter the hazard zone only when the…

1996-05-28-2 Opinion Letter May 28, 1996
US

Carbon dioxide displacement of oxygen hazard bulletin Unknown

OSHA agreed workers should be warned about oxygen displacement by carbon dioxide and said a hazard bulletin covering protective measures was being developed. OSHA archives this historical correspondence.

1996-05-28-1 Opinion Letter May 28, 1996
US

Approval of cut-resistant gloves under bloodborne pathogens standard

OSHA declined to approve or endorse cut- and puncture-resistant gloves for bloodborne pathogen protection. It said compliance depends on observed work practices and the potential exposure to blood…

1996-05-28-0 Opinion Letter May 28, 1996
US

Consumer product use under hazard communication

OSHA explained that hazardous consumer products are exempt from the Hazard Communication Standard when workplace use does not exceed the manner, frequency, and duration of consumer exposure. The…

1996-05-28 Opinion Letter May 28, 1996
US

Bar code records for fire safety equipment inspections

OSHA said a computerized bar code system had to capture all required fire-equipment inspection information, including required signatures and extinguisher identifiers. It also described its de…

1996-05-24 Opinion Letter May 24, 1996
US

Construction first aid instructor guide review Unknown

OSHA said the submitted guide covered required construction first aid procedures but should reflect that consulting-official approval of kits was no longer needed, address drenching where corrosive…

1996-05-23 Opinion Letter May 23, 1996
US

When state unemployment funds receive and expend money

ETA explained when money becomes part of a state's unemployment fund and when it leaves the fund under federal deposit and withdrawal rules. Contributions enter the fund as soon as the state or its…

UIPL No. 22-96 Guidance May 22, 1996
US

1996 technical amendments and state-plan notification Unknown

OSHA notified state-plan officials of a 1996 federal rule removing and consolidating regulatory text across several parts of Title 29. The memo said states were encouraged but not required to mirror…

1996-05-22-0 Interpretive Notice May 22, 1996
US

Asbestos glove-bag use and Class I repair work

A glove-bag maker asked OSHA to clarify how its asbestos rule treats larger glove bags. OSHA confirmed that a repair disturbing asbestos-containing material that cannot be contained in one standard…

1996-05-22 Opinion Letter May 22, 1996
US

Butterfly bandages under former injury log rules Unknown

OSHA said it did not regulate who could apply butterfly bandages or how they were applied. Under the former injury-log guidance, wound closures were medical treatment and ordinary wound coverings…

1996-05-21 Opinion Letter May 21, 1996
US

Treating physician name on former OSHA 101 report Unknown

OSHA said the former OSHA 101 form required the name and address of the treating physician when applicable, and a medical practice name alone was insufficient. It noted then-proposed changes to the…

1996-05-20-0 Opinion Letter May 20, 1996
US

Insulated tools and rubber gloves for energized electrical work Unknown

OSHA said its standards did not categorically require rubber insulating gloves whenever insulated hand tools were used. Qualified workers had to choose electrical protection suited to the task, and…

1996-05-20 Opinion Letter May 20, 1996
US

Proposed recordkeeping rule and de minimis citation policy Unknown

OSHA instructed field staff not to treat compliance with a proposed 1996 recordkeeping rule as a de minimis substitute for then-current requirements. Employers were to continue using the existing…

1996-05-15-3 Interpretive Notice May 15, 1996
US

Compressed air pressure testing of gas lines

A pipefitters' association asked whether OSHA has a rule on using compressed air to check gas lines for leaks. OSHA said no federal rule specifically addresses that test, but cited requirements for…

1996-05-15-2 Opinion Letter May 15, 1996
US

Silver exposure variance request and control methods

An employer sought a permanent variance from the silver metal exposure limit. OSHA declined to consider the request and explained that employers must use feasible engineering or administrative…

1996-05-15-0 Opinion Letter May 15, 1996
US

Safety oversight of hazardous-waste burning at cement kilns

An industry association asked whether OSHA should regulate hazardous-waste incineration at cement plants because MSHA lacked comparable standards. OSHA said MSHA remained the agency best suited to…

1996-05-15 Opinion Letter May 15, 1996
US

NFPA 33 compliance and OSHA spray-finishing citations

A product maker asked whether following the 1995 NFPA 33 spray-finishing standard offered equal or greater protection and would avoid an OSHA citation. OSHA said NFPA 33 offered at least equal…

1996-05-14 Opinion Letter May 14, 1996

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