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

Disability insurance benefits during FMLA leave

WHD answered whether an employer had to keep paying disability-insurance premiums during FMLA leave. It said disability insurance was outside the group health coverage that must be maintained,…

FMLA-6 Opinion Letter October 1, 1993
US

Life safety codes and OSHA exit requirements Unknown

An employer asked whether complying with NFPA 101 or a state building code satisfies OSHA exit rules. OSHA said NFPA 101 compliance meets its Subpart E requirements when the revised consensus…

1993-10-01 Opinion Letter October 1, 1993
US

Scheduling process hazard analyses by risk Unknown

A manufacturer asked whether it could analyze the most hazardous subunits first under the process safety management rule. OSHA accepted the proposed schedule if its priorities reflected the required…

1993-09-29 Opinion Letter September 29, 1993
US

Changes to leave benefits before FMLA took effect

WHD considered an employer that reduced paid disability leave before the FMLA took effect in August 1993. It said the new federal Act did not freeze preexisting benefit plans and allowed changes…

FMLA-5 Opinion Letter September 27, 1993
US

Hazard warnings for chemical labels and mixtures

A chemical company asked how specific label warnings must be and whether trace carcinogens must be disclosed in mixtures. OSHA said the warning must convey the actual hazard, including target organ…

1993-09-27-0 Opinion Letter September 27, 1993
US

Evaluating a suction system under the bloodborne pathogens rule

A device maker asked OSHA to endorse a suction system for use in medical offices under the bloodborne pathogens rule. OSHA declined to approve the product, explaining that compliance depends on…

1993-09-27 Opinion Letter September 27, 1993
US

Bloodborne pathogen coverage at pregnancy test centers

Pregnancy test centers asked whether the bloodborne pathogens rule applied to their staff. OSHA said it covers employees, based on reasonably anticipated exposure in their duties, including handling…

1993-09-24-0 Opinion Letter September 24, 1993
US

Confined-space enforcement at construction sites Unknown

A builders' association asked whether OSHA's new general-industry permit-space rule changed confined-space enforcement at construction sites. OSHA said it would cite applicable construction rules…

1993-09-23 Opinion Letter September 23, 1993
US

Documenting the flammable-liquid process safety exception Unknown

An employer asked what records support the process safety rule’s exception for flammable liquids stored in atmospheric tanks. OSHA said the exception is limited to storage and transfer equipment…

1993-09-20-3 Opinion Letter September 20, 1993
US

Recording bloodborne pathogen exposure incidents Unknown

An employer asked when bloodborne pathogen incidents had to be entered on the former OSHA 200 Log. OSHA distinguished incidents with no defined exposure from actual exposure incidents and explained…

1993-09-20-2 Opinion Letter September 20, 1993
US

Lost workday counts for temporary employees Unknown

A lawyer asked how to count lost workdays for an injured temporary worker whose assignment ends. OSHA said the count should reflect the lesser of the days the injury actually incapacitated the…

1993-09-20-1 Opinion Letter September 20, 1993
US

Employer duties for protective footwear and its cost Unknown

An employer asked whether the personal protective equipment standard required it to supply protective footwear without charging employees. OSHA said the employer had to assess foot hazards and…

1993-09-20-0 Opinion Letter September 20, 1993
US

Microwave treatment of regulated medical waste

An OSHA regional office asked whether a microwave system could turn regulated medical waste into regular waste. OSHA deferred the disposal decision to state and local authorities while federal…

1993-09-17-0 Opinion Letter September 17, 1993
US

Limits on OSHA approval of needle recapping devices

A medical device maker sought OSHA approval for a needle recapper, citing an earlier letter about another device. OSHA said it had not approved the earlier product either; it had only found that…

1993-09-15 Opinion Letter September 15, 1993
US

Liability and interest for reimbursing unemployment employers Unknown

ETA explained how states may make employers that reimburse unemployment benefits share unrecovered benefit costs, including through collective liability. It also described advance payments and…

UIPL No. 44-93 Guidance September 13, 1993
US

Plan fiduciary earnings on benefit-check float Unknown

A requester asked whether a trust company could keep interest earned while benefit checks remained uncashed. EBSA said a fiduciary exercising discretion over plan assets would engage in prohibited…

Advisory Opinion 1993-24A Opinion Letter September 13, 1993
US

Responsible party identified on material safety data sheets

A distributor asked whose contact details must appear on a material safety data sheet when it sells a manufacturer’s product under its own name. OSHA said the named responsible party must be able to…

1993-09-13-1 Opinion Letter September 13, 1993
US

Hazard communication for medications in medical offices

A medical office asked whether it needed safety data sheets for oral and injectable medications. OSHA said hazardous drugs can fall under the hazard communication rule, then described exemptions for…

1993-09-13-0 Opinion Letter September 13, 1993
US

Formaldehyde labels on medical waste containers

A medical waste handler asked whether outer cardboard boxes containing sealed bags of formalin-treated tissue need formaldehyde hazard labels. OSHA said its label rule applies to the container…

1993-09-13 Opinion Letter September 13, 1993
US

Keeping injury and illness logs at another location Unknown

An employer asked whether it could prepare and maintain the former OSHA 200 injury log away from the worksite. OSHA said the remote location needed information for timely entries and an updated copy…

1993-09-10 Opinion Letter September 10, 1993
US

Condominium managers as joint FMLA employers

WHD considered condominium associations with unpaid boards and a managing agent handling employee administration. It said a managing agent employing enough workers across associations could be a…

FMLA-4 Opinion Letter September 9, 1993
US

Equivalent job restoration after maternity leave

WHD answered a worker concerned about her job after maternity leave. It said an eligible employee returning from FMLA leave is entitled to the same or an equivalent position with equivalent pay,…

FMLA-3 Opinion Letter September 9, 1993
US

Mutual fund exemption for IRA investments Unknown

A bank asked whether an exemption for fiduciary-affiliated mutual fund investments could apply to IRAs it managed. EBSA said PTE 77-4 covers IRAs and other Code-covered accounts even when they are…

Advisory Opinion 1993-26A Opinion Letter September 9, 1993
US

Tagout procedures at hydroelectric powerhouses Unknown

A federal power project asked whether its tag-only clearance procedure could continue under OSHA energy-control rules. OSHA said it could not decide without an on-site review and explained the…

1993-09-09-6 Opinion Letter September 9, 1993
US

Process safety coverage for flammable gas and liquid operations Unknown

A lawyer asked nine questions about process safety management coverage at flammable gas and liquid facilities. OSHA explained how quantities, nearby vessels, connected equipment, storage exemptions,…

1993-09-09-5 Opinion Letter September 9, 1993
US

Technical considerations for tandem crane loads in steel erection Unknown

An OSHA regional office asked about lifting several steel members on one crane line, often called Christmas treeing. OSHA’s construction office discussed the technical risks, rigging practices, and…

1993-09-09-4 Opinion Letter September 9, 1993
US

Electrical safety training for qualified workers

A union asked what training workers need before servicing or testing electrical equipment. OSHA distinguished qualified and unqualified workers and said only qualified people may work on certain…

1993-09-09-3 Opinion Letter September 9, 1993
US

Moving oxygen-fuel cylinders with regulators attached

A consultant asked whether oxygen-fuel cylinders with regulators installed could be moved on a special cart. OSHA treated those cylinders as connected for use and said the cart must hold them…

1993-09-09-2 Opinion Letter September 9, 1993
US

Separate buildings under the employee alarm rule

An employer asked whether three structurally separate buildings connected by a corridor counted as one workplace under an employee alarm provision. OSHA said each building, with its own exits, was a…

1993-09-09-1 Opinion Letter September 9, 1993
US

Process safety coverage during hydrogen peroxide delivery

A manufacturer asked whether a tank-truck delivery of concentrated hydrogen peroxide brought its receiving process under OSHA's process safety rule. OSHA corrected an earlier answer, explained the…

1993-09-09-0 Opinion Letter September 9, 1993
US

Attendant position during LPG transfer

An employer asked what “close” means for an attendant monitoring an LPG transfer. OSHA said the attendant must be near enough to see problems and respond at the connection point until the transfer…

1993-09-09 Opinion Letter September 9, 1993
US

Safety standards for aerial work platforms Unknown

A foreign equipment supplier asked which U.S. safety rules applied to its aerial work platforms. OSHA said it had no platform-specific requirement for the models described, but cited consensus…

1993-09-08-0 Opinion Letter September 8, 1993
CA

A pre-employment 'trainee' screening process must be separate from, and not a condition of, employment screening

A personnel-services firm asked DLSE to confirm its proposed computer- skills training program for unemployed job seekers met the Division's twelve-factor test for a true "trainee" (as opposed to an…

1993.09.07 Opinion Letter September 7, 1993
US

Training when new chemical hazards enter the workplace

An employer asked whether comprehensive initial hazard communication training eliminates later retraining. OSHA said employers must review new chemical information and train affected employees when…

1993-09-07 Opinion Letter September 7, 1993
US

Dependent care reimbursements outside ERISA welfare-plan coverage Unknown

An employer asked whether its salary-reduction dependent care account was an ERISA welfare plan. EBSA distinguished reimbursement for care services chosen by each worker from an employer-provided…

Advisory Opinion 1993-25A Opinion Letter September 3, 1993
US

ERISA plan duties when Medicare seeks repayment Unknown

A requester asked how health plans should handle Medicare requests to recover payments Medicare made first. EBSA said fiduciaries must account for the federal Secondary Payer rules even when a…

Advisory Opinion 1993-23A Opinion Letter September 3, 1993
US

Generator grounding, extension cords, and trench shields Unknown

A safety consultant asked about extension cords and portable generators, fall protection, and using street plates with trench shields. OSHA explained the electrical and trench-shield requirements.…

1993-09-03-1 Opinion Letter September 3, 1993
US

Secondary wire ropes on suspended scaffolds

A scaffold association asked whether a secondary wire rope could attach to its own anchorage and to an outrigger, and whether a proposed trolley line was acceptable. OSHA said the rope setup could…

1993-09-03 Opinion Letter September 3, 1993
US

Lifting two empty shipping containers together Unknown

A marine operator proposed lifting two empty containers together using twist locks. OSHA said the operation could comply if it met eight conditions, including inspection, verified lock capacity,…

1993-09-02-0 Opinion Letter September 2, 1993
US

First-aid response proximity at worksites Unknown

An association asked what “near proximity” means for first-aid readiness. OSHA said first aid should begin within three to four minutes where life-threatening injuries are foreseeable, while a…

1993-09-02 Opinion Letter September 2, 1993
US

Insert earphones in occupational hearing tests Unknown

An equipment maker asked about using insert earphones for required occupational hearing tests. OSHA revised the conditions under which their use would be treated as a de minimis violation,…

1993-08-31-2 Opinion Letter August 31, 1993
US

Recording treatment complications after workplace injuries Unknown

A requester asked whether complications from treatment of workplace injuries changed the OSHA 200 Log. OSHA said additional lost days from physical therapy complications counted toward the original…

1993-08-31-1 Opinion Letter August 31, 1993
US

Multiple injury logs and job descriptions for floating workers Unknown

An employer asked whether it could keep multiple injury-log sets and how to list workers who move among departments. OSHA said extra sets were permissible if the current records were available to…

1993-08-31-0 Opinion Letter August 31, 1993
US

Hazard communication for sealed chemical sensors

A safety consultant asked whether small sensors containing corrosive chemicals were exempt as articles from hazard communication duties. OSHA said the exemption applies when normal use does not…

1993-08-31 Opinion Letter August 31, 1993
US

Ventilation rates for welding enclosures and hoods

A federal facility asked about minimum airflow rates for welding ventilation. OSHA said its enforcement approach at the time focused on whether ventilation kept harmful exposures below allowable…

1993-08-27 Opinion Letter August 27, 1993
US

Disposal and recapping of used radiopharmacy syringes

A radiopharmacy asked how the bloodborne pathogens rule applied to used unit-dose syringes returned from hospitals. OSHA said the used needles were contaminated sharps and regulated waste,…

1993-08-25 Opinion Letter August 25, 1993
US

Reporting pension separate-account assets on Form 5500 Unknown

A pension plan asked how to report investments held in an insurance company separate account. EBSA said the plan must include each underlying asset in the matching Form 5500 asset category, report…

Advisory Opinion 1993-22A Opinion Letter August 24, 1993
US

Petroleum-based hand creams and latex gloves

A health product company asked whether workers using latex gloves could use petroleum-based hand creams. OSHA said hand cream was permitted in exposure areas, but petroleum-based products could…

1993-08-24 Opinion Letter August 24, 1993
CA

A vacation-accrual cap that later drops to a lower cap after use is not a valid 'no additional accrual' policy

PayLess Drug Stores' counsel proposed a revised vacation policy allowing vacation to accrue day-by-day and carry over, but capping further accrual at roughly 17.5 days for nine months and then…

1993.08.18 Opinion Letter August 18, 1993
US

Recording injuries from fights on employer premises Unknown

An employer asked whether an injury from a fight on company premises counted as work related for the former OSHA injury log. OSHA said on-premises injuries were presumed work related, with limited…

1993-08-18-2 Opinion Letter August 18, 1993
US

When massage treatment made an injury recordable Unknown

An employer asked whether use of a hand-held massager made a case recordable on the former OSHA 200 Log. OSHA said preventive use without symptoms did not, while massage for a symptomatic worker…

1993-08-18-1 Opinion Letter August 18, 1993
US

Selecting the date of injury or illness for records Unknown

An employer asked which date belonged in an occupational injury or illness record. OSHA said to use the accident date for injuries and the initial diagnosis date for illnesses, or the earlier…

1993-08-18-0 Opinion Letter August 18, 1993
US

Attendance awards, vacation accrual, and bonuses on FMLA leave

WHD answered questions about attendance plans, vacation accrual and bonus pay during FMLA leave. It said protected leave cannot count against a no-fault attendance policy, but unpaid leave does not…

FMLA-2 Opinion Letter August 16, 1993
US

Safety Rail System under construction guardrail rules Unknown

An inventor asked whether a proposed rail system met OSHA construction rules. OSHA said it did not approve products, then listed the rule's requirements for height, strength, intermediate…

1993-08-13-1 Opinion Letter August 13, 1993
US

Drug safety data sheets in medical offices

A physician asked whether a medical office needed material safety data sheets for drugs. OSHA said FDA-regulated drugs can be covered, while solid final-form drugs for direct patient administration…

1993-08-13 Opinion Letter August 13, 1993
US

Extension cord indicators and grounding continuity tests

An OSHA region asked whether a light built into an extension cord proved grounding continuity. OSHA said the light showed only that the cord was energized; a proper continuity tester and the…

1993-08-09-0 Opinion Letter August 9, 1993
US

Formaldehyde pesticide labels and federal jurisdiction

Pesticide manufacturers asked whether OSHA formaldehyde labels were required for registered pesticide products. OSHA said federal pesticide law controlled labeling of those products and also limited…

1993-08-09 Opinion Letter August 9, 1993
US

JTPA dislocated-worker training as approved unemployment training Unknown

ETA told state unemployment agencies to treat qualifying dislocated workers who actually participate in Title III JTPA training, other than on-the-job training, as attending approved training for…

UIPL No. 36-93 Guidance August 6, 1993
US

Warning stickers on stump grinders

A lawyer asked whether OSHA required stump grinders to display a warning against use by people below a stated weight. OSHA said it had no regulation requiring that particular sticker and suggested…

1993-08-06 Opinion Letter August 6, 1993
US

Construction manager duties at multi-employer worksites Unknown

A lawyer asked about a construction manager’s duties on a site with several employers. OSHA said the manager could be cited when its own workers were exposed, when its direction created a hazard, or…

1993-08-05-1 Opinion Letter August 5, 1993

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