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 agency service and FMLA eligibility

WHD considered a worker supplied by a temporary agency and later hired directly by the client company. It said the agency and client were joint employers for FMLA coverage and eligibility, so the…

FMLA-37 Opinion Letter July 7, 1994
US

Lockout of valves with chains or covers Unknown

A chemical company asked whether chains, locks, or valve covers could satisfy OSHA’s lockout requirements, including for newly installed valves. OSHA said these could qualify when they effectively…

1994-07-07-1 Opinion Letter July 7, 1994
US

Process safety coverage of turpentine in wood digestion Unknown

A wood-products company asked whether turpentine stored in atmospheric tanks or used as lime-kiln fuel was exempt from OSHA’s process safety management rule. OSHA said storage alone did not…

1994-07-07-0 Opinion Letter July 7, 1994
US

Supervisor training for hazardous waste operations

The Army Corps asked which personnel needed the additional supervisor training under OSHA’s hazardous waste operations rule. OSHA said on-site managers and supervisors responsible for health and…

1994-07-07 Opinion Letter July 7, 1994
US

Alarms on portable breathing-air compressors

An OSHA regional administrator asked whether portable breathing-air compressors required carbon monoxide or high-temperature alarms. OSHA distinguished a prior letter about stationary compressors…

1994-07-05 Guidance July 5, 1994
US

Pilots union accidental death insurance under ERISA Unknown

A pilots union asked whether its accidental death and dismemberment coverage was outside ERISA as voluntary insurance. EBSA said the union endorsed it in branded materials, helped shape the plan,…

Advisory Opinion 1994-24A Opinion Letter July 1, 1994
US

Pilots union accident and sickness insurance under ERISA Unknown

A pilots union asked whether its accident and sickness coverage was outside ERISA as voluntary insurance. EBSA said union-branded materials endorsed it, the union contributed to the insurer's claims…

Advisory Opinion 1994-23A Opinion Letter July 1, 1994
US

Pilots union term life insurance under ERISA Unknown

A pilots union asked whether its group term life coverage was outside ERISA as voluntary insurance. EBSA said branded materials endorsed it, the union paid for some coverage, and it helped shape…

Advisory Opinion 1994-22A Opinion Letter July 1, 1994
US

Protective clothing for bloodborne pathogen exposure

A protective-equipment maker asked what quality criteria OSHA applied to clothing used against bloodborne pathogens. OSHA said it had no specific biological-resistance specification and that…

1994-07-01 Opinion Letter July 1, 1994
US

Requirements for federal approval of a state OSHA plan Unknown

A state employee asked how a state could obtain federal approval for its own occupational safety and health program. OSHA explained the application, state legal authority, standards, enforcement,…

1994-06-30 Opinion Letter June 30, 1994
US

Keys for locked exits and the meaning of occupied Unknown

An OSHA regional office asked how the exit rule applied to doors requiring a key from the egress side. OSHA said later NFPA definitions that treated a building as occupied only above a ten-person…

1994-06-29-0 Guidance June 29, 1994
US

Recording occupational hearing loss on OSHA Form 200 Unknown

A marine company asked when hearing loss had to be recorded on the former OSHA Form 200 log. OSHA described the then-used 25-decibel cumulative shift threshold, how a recordable audiogram became the…

1994-06-27 Opinion Letter June 27, 1994
US

Mandatory implementation of Revenue Quality Control Unknown

ETA laid out when state unemployment agencies would begin mandatory Revenue Quality Control reporting and review of tax operations. Computed measures and revised Form ETA 581 reporting were…

UIPL No. 32-94 Guidance June 24, 1994
US

Glutaraldehyde hazard information for health care workers

A member of Congress asked how workers using glutaraldehyde in health care would learn about newly identified hazards. OSHA said chemical makers and importers had to update safety data sheets after…

1994-06-24-0 Opinion Letter June 24, 1994
US

Notice of Extended Benefits status changes from unemployment rate trigger Unknown

ETA said it would notify a state official when the alternative three-month total unemployment rate changed the state's Extended Benefits status and explain the circumstances. States still had to…

UIPL No. 30-94 Guidance June 21, 1994
CA

Employment-application release-of-liability language cannot waive Labor Code section 1050 protections

A company voluntarily submitted a proposed employment application for DLSE's review. DLSE flagged the application's release-of-liability clause, under which an applicant released all parties from…

1994.06.21 Opinion Letter June 21, 1994
US

Emergency eyewash and showers in extreme temperatures Unknown

An equipment company asked how emergency eyewash and showers should work outdoors in freezing or hot conditions. OSHA said employers must provide reliable equipment that flushes corrosive material…

1994-06-21-0 Opinion Letter June 21, 1994
US

Bloodborne pathogen rules for human cell lines and strains

A biological safety association asked OSHA to clarify coverage of established human cell lines. OSHA said well-characterized lines shown free of bloodborne pathogens could fall outside the standard,…

1994-06-21 Opinion Letter June 21, 1994
US

Kentucky literacy center in county retirement system Unknown

Representatives of a county-created literacy center asked whether its participation in the county retirement system would affect the system's governmental-plan status. EBSA said the center was a…

Advisory Opinion 1994-21A Opinion Letter June 17, 1994
US

Association health and life program as a MEWA Unknown

A requester asked whether the described association health and life insurance program was a multiple employer welfare arrangement. EBSA said it was, because participation spanned more than one…

Advisory Opinion 1994-20A Opinion Letter June 17, 1994
CA

Golf instructors paid on commission fall under the Recreation Order, not the sales-commission exemption

An attorney representing a golf instruction company argued its commissioned instructors should fall under the occupational Wage Order 4 (to claim its commissioned-sales exemption) rather than the…

1994.06.17-2 Opinion Letter June 17, 1994
CA

Piece-rate/commission pay plan with a possible bonus is not a 'regular rate' and must be recomputed for overtime

An attorney submitted a proposed crew-based compensation plan and asked whether its structure satisfied California overtime law. DLSE explained the plan's "possible discretionary bonus" was not…

1994.06.17-1 Opinion Letter June 17, 1994
US

Flammable aerosol adhesives and spray-finishing rules

A manufacturer asked whether flammable aerosol adhesives used to bond wood panels fell under OSHA’s spray-finishing standard. OSHA said the described cans and cylinders were generally covered,…

1994-06-15-0 Opinion Letter June 15, 1994
US

Cadmium urine sampling and biological monitoring

A company asked how to obtain accurate urine samples for cadmium biological monitoring. OSHA said prehydration could make samples too dilute and recommended an initial sample without drinking water…

1994-06-15 Opinion Letter June 15, 1994
US

Religious Freedom Restoration Act and unemployment claims Superseded

In 1994, ETA told state unemployment agencies to apply the federal Religious Freedom Restoration Act when a state rule burdened a claimant's religious practice. The letter reviewed earlier Supreme…

UIPL No. 28-94 Guidance June 13, 1994
US

Appalachian Regional Commission pension as governmental plan Unknown

The Appalachian Regional Commission asked whether its pension plan qualified for ERISA’s governmental exemption. EBSA said the commission was a federal and state instrumentality created, controlled,…

Advisory Opinion 1994-19A Opinion Letter June 13, 1994
US

Interim fall protection policy for roofing work Unknown

OSHA told field offices how to cite fall-protection violations in steep-roof and built-up roofing work while a new construction rule was pending. The memorandum limited citations to failures under…

1994-06-13-0 Guidance June 13, 1994
US

Cleaning blood-contaminated carpet under OSHA rules

A supplier asked how employers should handle blood or other potentially infectious material spilled on carpet. OSHA withdrew its earlier suggestion that plush carpet could be decontaminated, saying…

1994-06-10 Opinion Letter June 10, 1994
US

Process safety coverage of hazardous chemical mixtures Unknown

An environmental services company asked when gases and mixtures of listed hazardous chemicals fell under OSHA’s process safety management rule. OSHA explained how Appendix A listings,…

1994-06-09 Opinion Letter June 9, 1994
US

Confined-space settlement and gas industry coverage

OSHA circulated a settlement concerning its confined-space standard and gas-industry operations. The memo said Department of Transportation pipeline rules governed many such operations, including…

1994-06-01-1 Guidance June 1, 1994
US

Davit-arm hoisting of workers in a boatswain chair Unknown

A company asked whether a dedicated davit-arm system could lift workers in a boatswain chair during submarine ballast-can work. OSHA said the described system appeared safe and feasible and would…

1994-06-01-0 Opinion Letter June 1, 1994
US

Process safety threshold quantity for ammonia systems

A safety consultant asked whether a large ammonia system triggered process safety rules when it was filled below the threshold quantity. OSHA said coverage depended on the amount actually present at…

1994-06-01 Opinion Letter June 1, 1994
US

Historical reporting of multiple hospitalizations Unknown

A lawyer asked how OSHA’s then-current fatality and multiple-hospitalization reporting rule counted workers from different employers. OSHA confirmed that the duty applied to an employer’s own…

1994-05-26-0 Opinion Letter May 26, 1994
US

Recording back injuries and carpal tunnel on Form 200 Unknown

A risk manager asked when back injuries and carpal tunnel cases belonged on the former OSHA Form 200. OSHA said workers’ compensation decisions did not control the log; work-related carpal tunnel…

1994-05-25-3 Opinion Letter May 25, 1994
US

Chimney platform gaps and falling-object protection Unknown

An engineering firm asked whether a narrow gap between a chimney and surrounding work platform was allowed and when toeboards were needed. OSHA said the proposed two-inch gap was within the…

1994-05-25-2 Opinion Letter May 25, 1994
US

Respirator exhalation valve leakage and tuberculosis

Health care employers asked whether valved respirators exposed workers to tuberculosis through inward leakage. OSHA said properly maintained exhalation valves leaked very little and a valveless…

1994-05-25 Guidance May 25, 1994
US

Princeton Theological Seminary employee plans as church plans Unknown

A Presbyterian seminary asked whether its employee benefit arrangements were church plans. EBSA said the church’s control of the seminary and its associated plan committee met the church plan…

Advisory Opinion 1994-18A Opinion Letter May 23, 1994
US

Tag lines for structural steel lifting Unknown

A crane training institute asked whether tag lines were required every time a structural steel load moved. OSHA said the then-applicable rule required control of hazardous loads, so tag lines were…

1994-05-20 Opinion Letter May 20, 1994
US

Needlestick injuries on the former OSHA Form 200 Unknown

A health care organization asked when needlestick injuries belonged on the former OSHA Form 200. OSHA listed the then-used triggers, including work restriction, medical treatment beyond first aid,…

1994-05-19-1 Opinion Letter May 19, 1994
US

Recording heat-related disorders on OSHA Form 200 Unknown

A law firm asked when heat-related illness had to be recorded on the former OSHA Form 200. OSHA said diagnosed or recognized work-related heat rash, cramps, exhaustion or stroke were recordable, and…

1994-05-19-0 Opinion Letter May 19, 1994
US

Foot protection against falling objects at construction sites

A senator asked whether OSHA required steel-toed shoes for all workers exposed to falling objects. OSHA said the cited fall-protection rule did not impose a blanket steel-toed-shoe requirement;…

1994-05-19 Opinion Letter May 19, 1994
US

Postal worker sick leave for newborn care

WHD considered a Postal Service employee who wanted to use accrued sick leave while taking FMLA leave to care for a newborn. It said the FMLA's paid-leave substitution rule did not require that use…

FMLA-36 Opinion Letter May 18, 1994
US

Aqueous hydrofluoric acid and process safety coverage

A company asked whether aqueous hydrofluoric acid fell under OSHA’s process safety management listing for anhydrous hydrogen fluoride. OSHA said aqueous solutions such as 49 percent hydrofluoric…

1994-05-18 Opinion Letter May 18, 1994
US

Bloodborne pathogen rule and construction workers

A construction safety director asked how OSHA’s bloodborne pathogens rule applied at construction sites. OSHA said construction work itself was outside that rule, but covered maintenance staff or…

1994-05-13 Opinion Letter May 13, 1994
US

Dual JTPA and senior employment program eligibility Rescinded

ETA answered eight questions about joint projects under the Job Training Partnership Act and the Senior Community Service Employment Program. It said written agreements can allow eligible senior…

TEGL No. 09-93 Guidance May 12, 1994
US

Completing the former OSHA Form 101 Unknown

A manufacturer asked which fields of the former OSHA Form 101 had to be completed and what to do when facts were missing. OSHA said all questions had to be addressed within six workdays, unknown…

1994-05-12-0 Opinion Letter May 12, 1994
US

Voluntary overtime as lost workdays on Form 200 Unknown

A company asked whether missed voluntary weekend overtime counted as lost workdays after a work-related injury or illness. OSHA said it counted if the worker was scheduled or had a clear pattern of…

1994-05-12 Opinion Letter May 12, 1994
US

Lifting two loaded freight containers together Unknown

A longshore union asked whether two loaded freight containers could be hoisted together using locking cones. OSHA said the practice was unsafe because shifting cargo made loads on the connectors…

1994-05-11 Opinion Letter May 11, 1994
US

Disinfectants for blood spills on hard surfaces and carpet Unknown

A cleaning company asked which products it could use after blood or other potentially infectious material spills. OSHA described its then-current disinfectant policy for hard surfaces, while saying…

1994-05-06 Opinion Letter May 6, 1994
US

Recordkeeping exemption for motor vehicle dealerships Unknown

OSHA told regional recordkeeping staff that some motor vehicle dealerships had been cited for lacking the former injury and illness logs. The memo said SIC 55 was normally exempt under the…

1994-05-03 Guidance May 3, 1994
US

Annual written tests in place of refresher training Unknown

A company asked whether a properly designed test could replace repeated annual safety training. OSHA said an annual written test might suffice where hazards and duties remained the same, but a test…

1994-05-02 Opinion Letter May 2, 1994
US

COBRA initial notice to an uncovered spouse Unknown

An individual asked whether group health plans must send a COBRA initial notice to an employee’s spouse even when the spouse was not covered. EBSA said the notice duty for a spouse arises only when…

Advisory Opinion 1994-17A Opinion Letter April 29, 1994
US

Needle recapping device under bloodborne pathogen rules

An inventor asked OSHA to assess a device meant to cover used needles before disposal. OSHA said it did not endorse products, but the described device appeared to be a recapping tool rather than a…

1994-04-29 Opinion Letter April 29, 1994
US

Impermeable bags for asbestos waste disposal

A bag manufacturer asked what specifications and tests OSHA required for asbestos waste bags. OSHA said its standards set performance requirements rather than prescriptive bag tests: the bag must be…

1994-04-26-2 Opinion Letter April 26, 1994
US

Asbestos monitoring and PPE during emergency response

A utility asked whether real-time instruments could justify reducing protective equipment during an asbestos release. OSHA said the asbestos and emergency-response rules both applied, with the more…

1994-04-26-1 Opinion Letter April 26, 1994
US

Source-patient blood testing after workplace exposure

A hospital asked whether it needed a separate physician order before testing a source patient’s blood after an employee exposure. OSHA said a hospital policy could provide for testing without that…

1994-04-26-0 Opinion Letter April 26, 1994
US

Cadmium content and labeling of installed products

A manufacturer asked when installed products containing trace cadmium needed a visible indication. OSHA said labeling was required at 0.1 percent cadmium or more, and below that level when evidence…

1994-04-26 Opinion Letter April 26, 1994
US

Testing compressed breathing air and compressor alarms

A refinishing-products company asked how OSHA interpreted compressor alarms and breathing-air quality checks. OSHA said an oil-lubricated compressor alarm had to be audible, that testing frequency…

1994-04-25-1 Opinion Letter April 25, 1994
US

Growers association as joint employer under field sanitation rule

A farmworker group asked whether a Virginia growers association shared responsibility for field sanitation. On the facts presented, OSHA said the association was a joint employer under the federal…

1994-04-25-0 Opinion Letter April 25, 1994
US

Reusable and disposable tracheostomy cannulas under the bloodborne pathogen rule

A medical-device maker asked what protective measures a caregiver should take when re-cleaning a patient's inner cannula and whether disposable inner cannulas could be an engineering control. OSHA…

1994-04-25 Opinion Letter April 25, 1994

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