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

Tuberculosis exposure controls in a care facility Unknown

A congressional office asked whether new tuberculosis rules were imminent and what a care facility should do with suspected cases. OSHA described early identification, prompt transfer to a suitable…

1995-09-20-0 Opinion Letter September 20, 1995
US

Eyeglass holders under full-face respirators

A fire department asked whether an eyeglass holder could be worn under a full-face respirator or breathing apparatus. OSHA said it would not accept an attachment between the mask seal and the…

1995-09-20 Opinion Letter September 20, 1995
US

Annual lockout procedure inspections and employee reviews Unknown

A law firm asked whether annual lockout inspections had to cover every machine and every employee, and whether refresher training could replace review. OSHA said each energy-control procedure needed…

1995-09-19-1 Opinion Letter September 19, 1995
US

Radiation dosimetry under OSHA and NRC standards

A radiation-control group asked whether OSHA's monitoring rule would permit a proposed effective-dose calculation based on shielded and collar dosimeters. OSHA said its ionizing-radiation standard…

1995-09-19-0 Opinion Letter September 19, 1995
US

Tying off inside an aerial lift Unknown

A worker suggested tying an aerial-lift lanyard to an overhead structure instead of the lift's boom or basket. OSHA rejected that approach under the cited 1995 rule, saying a lift attachment reduced…

1995-09-19 Opinion Letter September 19, 1995
US

Hazard-communication coverage of animal-feed ingredients

An animal-feed association asked OSHA to exempt feed ingredients from hazard-communication requirements because FDA rules also covered them and data sheets were burdensome. OSHA said FDA's rules did…

1995-09-18-0 Opinion Letter September 18, 1995
US

Suspended-load variance analysis for spacecraft lifting Unknown

OSHA staff reviewed a proposed variance that would let employees work beneath a suspended spacecraft. The memo recommended denial because the proposed practices did not provide protection equivalent…

1995-09-18 Guidance September 18, 1995
US

FMLA medical certification form and provider fees

WHD responded to a health care provider's concern that its optional FMLA certification form sought sensitive information and took time to complete. It said a provider need not complete the form,…

FMLA-71 Opinion Letter September 14, 1995
US

Bloodborne-pathogen duties for emergency responders and Ryan White Act

An infection-control consultant asked whether OSHA's bloodborne-pathogens rule displaced Ryan White Act procedures for emergency responders and who could determine an exposure incident. OSHA…

1995-09-12 Opinion Letter September 12, 1995
US

Steel erection and construction fall-protection plans Superseded

A steel erector asked OSHA to review a fall-protection plan under the general construction rule. OSHA said most described work fell under steel-erection provisions that did not then provide for such…

1995-09-11-5 Opinion Letter September 11, 1995
US

Faucet-mounted eyewash devices and flushing temperature Unknown

An eyewash maker asked OSHA to clarify acceptance of its faucet-mounted unit and the risk of hot flushing water. OSHA said the described unit met the consensus standard on the evidence supplied,…

1995-09-11-4 Opinion Letter September 11, 1995
US

Commercial-grade hydroxylamine under process safety rules Unknown

A manufacturer asked whether a 50% hydroxylamine solution was covered by process safety management requirements. OSHA said the listed chemical without a concentration limit was covered at…

1995-09-11-3 Opinion Letter September 11, 1995
US

Keeping injury logs at a central office Unknown

A company asked whether it could maintain injury logs centrally and fax them to individual sites when requested. OSHA said the then-current rule allowed an alternate log location if entries could be…

1995-09-11-2 Opinion Letter September 11, 1995
US

Whose log records a truck driver's injury offsite Unknown

A trucking association asked which employer recorded a driver's injury at another company's worksite. OSHA said the driver’s own employer kept the log when the other company did not supervise the…

1995-09-11-1 Opinion Letter September 11, 1995
US

Protective equipment during marine oil-spill response

A marine spill-response company asked whether OSHA's emergency-response rules forced workers to wear heavy respiratory gear when monitoring showed no inhalation hazard. OSHA said the employer could…

1995-09-11-0 Opinion Letter September 11, 1995
US

Refunding mistaken multiemployer plan withdrawal liability Unknown

A terminated multiemployer pension plan found computer errors that had overstated some employers’ withdrawal liability and asked whether it could refund payments without a formal challenge. EBSA…

Advisory Opinion 1995-24A Opinion Letter September 8, 1995
US

House-foundation excavation policy and trench hazards

A construction engineer questioned OSHA's policy treating house-foundation excavations differently from utility trenches under stated conditions, including its lack of a depth limit. OSHA…

1995-09-07-1 Opinion Letter September 7, 1995
US

Former OSHA enforcement policy for tuberculosis exposure Unknown

OSHA issued field staff an enforcement policy for respiratory protection against tuberculosis using then-current CDC guidance. The agency later struck information that no longer reflected its policy…

1995-09-06 Interpretive Notice September 6, 1995
US

Crane-suspended personnel platforms for tall stack erection Unknown

A contractor asked whether crane- or derrick-suspended personnel platforms could be used during stack and chimney erection. OSHA said the submitted arrangement met the intent of the cited rule for…

1995-09-05-3 Opinion Letter September 5, 1995
US

Awareness-level training for hazardous-release witnesses

An Air Force official asked which employees needed first-responder awareness training under the hazardous-release rule. OSHA said any employee expected to discover or witness an uncontrolled release…

1995-09-05-0 Opinion Letter September 5, 1995
US

Bloodborne-pathogen duties for child-care workers

A state health official asked whether child-care employees were covered by OSHA's bloodborne-pathogens rule and sought relief from hepatitis B vaccination duties. OSHA said coverage depended on…

1995-09-01-1 Opinion Letter September 1, 1995
US

Fall-protection criteria for power-distribution maintenance Unknown

A power-distribution employer asked whether revised construction fall-protection rules changed the general-industry rules for maintenance crews. OSHA said the maintenance duties remained the same;…

1995-09-01-0 Opinion Letter September 1, 1995
US

CSA marks on double-insulated electric tools

A power-tool company asked whether a Canadian Standards Association mark could show compliance for double-insulated portable electric tools. OSHA said CSA was a nationally recognized testing…

1995-09-01 Opinion Letter September 1, 1995
US

TRA qualification after a first TAA separation Withdrawn

ETA told state agencies that a trade-affected worker did not have to establish unemployment insurance entitlement during the TAA certification period to qualify for Trade Readjustment Allowances. It…

UIPL No. 42-95 Guidance August 31, 1995
US

Contingent equity incentive program under ERISA Unknown

A securities company asked whether a ten-year contingent equity incentive program was an ERISA benefit plan. EBSA said the stated terms provided neither a welfare benefit nor retirement income or…

Advisory Opinion 1995-23A Opinion Letter August 30, 1995
US

Needles and needleless systems for IV medication Unknown

A physician asked whether OSHA required needleless systems for intravenous drug administration. OSHA said the bloodborne-pathogens rule then in force did not ban sharps or mandate needleless…

1995-08-28-3 Opinion Letter August 28, 1995
US

Bloodborne-pathogen rules for diluted sewage and waste labels

A device maker asked when blood diluted into a sewer stopped being regulated waste and whether OSHA would approve its product label. OSHA said ordinary diluted sewage was generally outside the…

1995-08-28-2 Opinion Letter August 28, 1995
US

Frequency setting for fall-arrest equipment testing

A safety-equipment company questioned the 500 Hz frequency setting in OSHA's nonmandatory appendix for fall-arrest testing. OSHA agreed 100 Hz was more appropriate and said inspectors would not cite…

1995-08-28-1 Opinion Letter August 28, 1995
US

HAZWOPER training for emergency medical crews

An emergency-medical trainer asked what HAZWOPER training ambulance crews needed across several hazardous-material scenarios. OSHA said duties and the emergency plan determined the level: awareness…

1995-08-28 Opinion Letter August 28, 1995
US

Attendants, ventilation, and scissor-lift anchorage

A safety firm asked when a confined-space entry needed an attendant, whether a radio could replace one, and whether guarded scissor lifts needed lanyards. OSHA described two limited entry cases…

1995-08-25 Opinion Letter August 28, 1995
US

Common control and leased workers in a group health plan Unknown

A group of transport and leasing companies asked whether their shared health plan was a multiple employer welfare arrangement. EBSA said the wholly owned companies formed one control group, so…

Advisory Opinion 1995-22A Opinion Letter August 25, 1995
US

Kansas county hospital employee plans as governmental plans Unknown

A Kansas county hospital asked whether its health, insurance, and retirement arrangements were governmental plans. EBSA found the county-owned hospital was a government instrumentality because the…

Advisory Opinion 1995-21A Opinion Letter August 25, 1995
US

Review of a proposed roofing guardrail system Unknown

A roofing-equipment company asked OSHA to review its guardrail system. OSHA said it did not endorse products generally, but the system appeared to comply with the fall-protection rules if used as…

1995-08-25-0 Opinion Letter August 25, 1995
US

Manufacturer approval and repair of damaged mobile cranes Unknown

A crane owner asked if a damaged boom could be repaired without the manufacturer's approval. OSHA's August 24, 1995 response said major repairs should be reviewed and approved by the manufacturer or…

1995-01-18-0 Opinion Letter August 24, 1995
US

Counting overtime toward FMLA hours of service

WHD addressed the 1,250-hour service test for FMLA eligibility. Overtime hours actually worked count the same as regular hours, without multiplying them for any overtime pay premium. Vacation, sick…

FMLA-70 Opinion Letter August 23, 1995
US

Grand Rapids transit pension as governmental plan Unknown

A transit pension plan asked whether it became a governmental plan after a public transit authority took over the former private operator’s employees and sponsorship. EBSA said the authority was a…

Advisory Opinion 1995-20A Opinion Letter August 23, 1995
US

Testing deenergized power lines before grounding Unknown

A utility asked whether buzzing a power line was enough to verify it was deenergized before grounds were installed. OSHA said a high-voltage detector was preferred and buzzing was permitted only…

1995-08-23-0 Opinion Letter August 23, 1995
US

Recording disease exposures and vaccination boosters Unknown

A state labor agency asked whether possible disease exposure without injury belonged on OSHA's former injury log and whether a hepatitis booster changed the answer. OSHA said possible exposure alone…

1995-08-22 Opinion Letter August 22, 1995
US

Radio anti-two-block device on personnel cranes Unknown

A device maker asked whether a radio anti-two-block system met OSHA requirements for cranes suspending personnel platforms. OSHA said it did not approve products generally, but the described system…

1995-08-18-0 Opinion Letter August 18, 1995
US

Injuries during voluntary workplace blood drives Unknown

An employer asked for an exception from recording injuries that occurred when workers voluntarily donated blood at an onsite drive. OSHA declined a company-specific exception but changed its general…

1995-08-15-1 Opinion Letter August 15, 1995
US

Correcting injury logs and estimating lost workdays Unknown

A recordkeeping-system company asked how employers could correct entries, count lost workdays, and handle cases still continuing when logged. OSHA said the method of correction was flexible if…

1995-08-15-0 Opinion Letter August 15, 1995
US

Lockout duties of USDA meat and poultry inspectors Unknown

OSHA field offices asked whether USDA food-safety inspectors counted as authorized or affected employees under lockout and tagout rules. OSHA said the agency needed a lockout program and inspectors'…

1995-08-14 Interpretive Notice August 14, 1995
US

PSM exception for storage and transfer of flammable liquids Unknown

A chemical-distribution consultant asked whether storage, transfer, and the described nonmechanical blending of flammable liquids triggered process safety management requirements. OSHA said the…

1995-08-11-3 Opinion Letter August 11, 1995
US

Rebar climbing policy limited to built-in-place assemblies Unknown

A steel firm asked OSHA to extend its fall-protection interpretation for climbing rebar to assemblies hoisted into place. OSHA said the then-current exception was limited to the work addressed in…

1995-08-11-2 Opinion Letter August 11, 1995
US

HAZWOPER and hazard labels at waste transfer facilities

A hazardous-materials transport group asked what OSHA training, emergency-response, and labeling duties applied at waste transfer facilities. OSHA said coverage depended on the facility's regulated…

1995-08-11-1 Opinion Letter August 11, 1995
US

Site PPE plans and annual HAZWOPER medical exams

An environmental consulting firm asked whether its signed site safety plans met PPE assessment duties and whether annual HAZWOPER medical exams had to occur on an exact anniversary. OSHA said…

1995-08-11-0 Opinion Letter August 11, 1995
US

Blood-product labels and variance request

A company asked OSHA for a variance from bloodborne-pathogens label rules on behalf of blood-product suppliers. OSHA said containers labeled with their contents and released for transfusion or other…

1995-08-11 Opinion Letter August 11, 1995
US

Reporting JTPA Title II-A and II-C performance status Rescinded

ETA told states how to report each JTPA service delivery area's performance under Titles II-A and II-C. A state had to submit a technical assistance plan after a first failed program year and a…

TEGL No. 02-95 Guidance August 10, 1995
US

Guarded walkways over narrow excavations

A utility contractor group asked when a crossing over an excavation needed a guarded walkway. OSHA said it treated crossings of trenches 30 inches wide or less as de minimis and required guarded…

1995-08-10-0 Opinion Letter August 10, 1995
US

Enforcing apparel protection for electrical utility workers

OSHA gave inspectors interim guidance on enforcing apparel requirements for employees near energized power equipment. It explained how to evaluate clothing that could ignite, melt, or worsen arc or…

1995-08-10 Interpretive Notice August 10, 1995
US

Plan loans across collective bargaining units Unknown

An employer asked whether offering retirement plan loans only to bargaining units that had agreed to a loan feature violated ERISA’s reasonably equivalent access rule. EBSA said the phased approach…

Advisory Opinion 1995-19A Opinion Letter August 9, 1995
US

Logging short-lived occupational illness symptoms Unknown

An employer asked when short-lived symptoms counted as a recordable occupational illness. OSHA said its then-current system logged an abnormal condition caused or contributed to by a…

1995-08-07-0 Opinion Letter August 7, 1995
US

Ethylene oxide medical surveillance examinations

A hospital asked what medical tests it had to provide for employees working with ethylene oxide. OSHA identified the required examination elements, including a complete blood count, and said the…

1995-08-07 Opinion Letter August 7, 1995
US

Paint spray booths and NFPA 33 editions

A paint spray booth supplier asked if equipment meeting NFPA 33-1989 complied with OSHA rules. OSHA said its rule had incorporated the 1969 edition and would treat compliance with the 1989 edition…

1995-08-03 Opinion Letter August 3, 1995
US

Heat and cold therapy in injury recordkeeping Unknown

An employer asked how to classify hot, cold or physical therapy for injury and illness logs. OSHA said treatment at the first health care visit counted as first aid under its then-current…

1995-08-02 Opinion Letter August 2, 1995
US

Master keys for personal lockout devices Unknown

An employer asked whether a master key could remove an employee’s personal lockout padlock. OSHA said master and duplicate keys were not acceptable; when the employee was unavailable, the employer…

1995-07-28-1 Opinion Letter July 28, 1995
US

Connected methanol storage under process safety rules Unknown

A company asked whether atmospheric methanol storage tanks were exempt from OSHA’s process safety management rule. OSHA said the storage exemption applied to storage facilities and transfer conduits…

1995-07-28 Opinion Letter July 28, 1995
US

Adopted children’s group health coverage under ERISA Unknown

An adoption organization asked when ERISA group health plans must cover a child placed for adoption. EBSA said coverage begins when the participant or beneficiary assumes a legal support obligation…

Advisory Opinion 1995-18A Opinion Letter July 27, 1995
US

Disaster assistance benefit computation, July–September 1995 Withdrawn

ETA directed state unemployment agencies to use an attached state table when calculating Disaster Unemployment Assistance for major disasters declared from July through September 1995. The table…

UIPL No. 39-95 Guidance July 25, 1995
US

Tree trimming near electric supply lines Unknown

A risk manager asked whether employees trimming park trees near power lines were covered by OSHA’s electric power standard. OSHA said line-clearance work within the stated distance was covered,…

1995-07-25 Opinion Letter July 25, 1995

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