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

Backup alarms on industrial trucks at maritime worksites Unknown

A maritime employer asked whether powered industrial trucks needed backup alarms. OSHA said the cited maritime and general industry rules did not expressly require an alarm, but existing alarms…

1993-06-10 Opinion Letter June 10, 1993
US

Lockout and radiation hazards at television towers Unknown

A state attorney general asked whether OSHA’s lockout rule applied to television transmission towers. OSHA said the telecommunications rule left other applicable standards in force and that lockout…

1993-06-09-0 Opinion Letter June 9, 1993
US

Permanent job changes and restricted-workday counts Unknown

An employer asked when to stop counting restricted days on the former injury log. OSHA said a permanent modified assignment ended the count once the worker could perform all duties of the new job,…

1993-06-07-1 Opinion Letter June 7, 1993
US

Recording bloodborne pathogen exposure incidents Unknown

A gas industry association asked when bloodborne pathogen exposure incidents had to be logged. OSHA said incidents were evaluated as injuries and became recordable with specified work consequences,…

1993-06-07-0 Opinion Letter June 7, 1993
US

Forklift use in combustible dust atmospheres

A state labor official asked whether an ordinary powered industrial truck could dump hexamine where combustible dust clouds might form. OSHA said the described operation violated the cited…

1993-06-03-1 Opinion Letter June 3, 1993
US

Process hazard analysis deadlines with one or two covered processes Unknown

An employer asked how process hazard analysis percentage deadlines applied at sites with just one or two covered processes. OSHA said a single covered process generally had to be analyzed in full by…

1993-06-03-0 Opinion Letter June 3, 1993
US

Revised first-aid response times for construction sites Unknown

A construction employer asked how near medical help needed to be. OSHA revised its earlier answer, saying first aid should begin within three to four minutes where life-threatening injuries were…

1993-06-02-0 Opinion Letter June 2, 1993
US

Bloodborne pathogen coverage for ear-piercing workers

An OSHA region asked whether ear-piercing workers were covered by the bloodborne pathogens rule. OSHA said blood contact during piercing was part of their main job, and employers had to evaluate the…

1993-06-02 Opinion Letter June 2, 1993
US

Physical qualifications for crane operators Unknown

An equipment operator asked whether physical requirements printed in an OSHA training manual barred him from crane work. OSHA said those criteria came from an older consensus standard and that its…

1993-06-01 Opinion Letter June 1, 1993
US

Western Growers Assurance Trust as a MEWA Unknown

A requester asked whether a California growers' health trust escaped MEWA status because some benefits appeared in union contracts. EBSA found the employer-controlled trust could set prices and…

Advisory Opinion 1993-19A Opinion Letter May 28, 1993
US

Transfer of terminated truckdrivers legal-plan assets Unknown

Counsel for jointly administered labor-management trusts asked whether a terminated legal-services plan could transfer excess assets to a related welfare plan. EBSA said shared trustees alone do not…

Advisory Opinion 1993-18A Opinion Letter May 28, 1993
US

Recording occupational bloodborne pathogen exposure incidents Unknown

An employer asked when a bloodborne pathogen exposure belongs on its injury log. OSHA said contact with non-intact skin or mucous membranes may be recordable when it results in specified…

1993-05-27-2 Opinion Letter May 27, 1993
US

Fire extinguisher training and incipient fire brigade monitors

A chemical facility asked about extinguisher training and whether its incipient stage fire brigade could use large water monitors. OSHA said the described annual training met the extinguisher…

1993-05-27-1 Opinion Letter May 27, 1993
US

Bloodborne pathogen precautions in organized sports

A sports medicine physician proposed precautions for bleeding athletes. OSHA said employers must identify workers with occupational exposure, agreed that trainers and team physicians would have…

1993-05-27 Opinion Letter May 27, 1993
US

Recording bloodborne pathogen injuries on the OSHA 200 Log Unknown

An industry association asked when bloodborne exposure should be entered on the OSHA 200 Log. OSHA said an exposure to mucous membranes, non-intact skin or through the skin was recordable when it…

1993-05-24-2 Opinion Letter May 24, 1993
US

Recording an injury during business trip recreation Unknown

An employer asked whether to keep a snowmobiling injury from a business trip on its OSHA 200 Log. OSHA said the answer depended on whether the activity involved transacting or promoting business; if…

1993-05-24-1 Opinion Letter May 24, 1993
US

Recording burns and antiseptic treatment Unknown

An employer asked when burns and treatment with antiseptics were recordable on the OSHA 200 Log. OSHA said non-pinhead second degree and all third degree work-related burns were recordable…

1993-05-24-0 Opinion Letter May 24, 1993
US

Recording cumulative trauma disorders on the OSHA 200 Log Unknown

An employer asked whether an employee’s stiffness should be recorded as a cumulative trauma disorder. OSHA said a subjective symptom without medical treatment, lost workdays or job transfer did not…

1993-05-24 Opinion Letter May 24, 1993
US

Hatch Net fall protection and opening guards Unknown

OSHA sent its regional office a unified reply about a proposed hatch safety net. The attached letter said then-current opening rules required guards or covers, so the net was not equivalent…

1993-05-21 Guidance May 21, 1993
US

Distributing the UCFE agricultural-board coverage ruling to tax and appeals staff

ETA told state agencies to give the UCFE agricultural-board coverage ruling from UIPL 23-92 to tax and appeals staff, who had been omitted from the original distribution. It repeated that employees,…

UIPL No. 23-92, Change 1 Guidance May 20, 1993
US

Transfer of terminated carpenters legal-fund assets Unknown

Carpenters fund trustees asked whether a terminated legal-services plan could move its remaining assets to a related welfare fund. EBSA said common trustees alone do not make plans parties in…

Advisory Opinion 1993-16A Opinion Letter May 18, 1993
US

Transfer of Alaska laborers legal-fund assets Unknown

A requester asked whether a terminated Alaska legal-services fund could transfer remaining money to a related health and welfare fund. EBSA said the plans were not parties in interest merely because…

Advisory Opinion 1993-15A Opinion Letter May 18, 1993
US

OSHA jurisdiction over injuries to members of the public

A person asked OSHA for help with an injury claim involving a moving company. OSHA said its statute addresses employer duties to employees at work, not injuries to members of the public caused by…

1993-05-18 Opinion Letter May 18, 1993
US

Recording fractures, burns, eye injuries and treatment Unknown

An employer asked about several injury recording situations. OSHA described when fractures, second degree burns, eye treatment and repeated heat or cold therapy were recordable under its…

1993-05-17 Opinion Letter May 17, 1993
US

Hazard communication labels for fire extinguishers

A fire protection company asked whether hazardous chemical labeling rules applied to fire extinguishers. OSHA said extinguishers containing hazardous chemicals, including compressed gas, required…

1993-05-15 Opinion Letter May 15, 1993
US

Alternative methods for Benefits Quality Control investigations Unknown

ETA directed state agencies to begin using revised methods for Benefits Quality Control investigations in July 1993. It retained in-person claimant interviews and generally in-person work-search…

UIPL No. 27-93 Guidance May 13, 1993
US

Hazard communication coverage of drugs in veterinary work

A lawmaker asked how the Hazard Communication Standard applied in veterinary practices. OSHA said hazardous drugs and chemicals are covered, with exceptions for certain retail consumer packages,…

1993-05-11 Opinion Letter May 11, 1993
US

Generic safety data sheets for fertilizer mixtures

A consultant asked whether fertilizer makers needed a separate material safety data sheet for every nutrient combination. OSHA said a generic sheet could cover mixtures with the same hazards if it…

1993-05-07 Opinion Letter May 7, 1993
US

Process safety coverage of flammable spray painting Unknown

A manufacturer asked whether flammable paint used in spray operations triggered process safety management. OSHA said covered operations depended on the 10,000 pound threshold and how a process or…

1993-05-06 Opinion Letter May 6, 1993
US

Employer premium trust and medical plan assets Unknown

An employer asked whether money it set aside in a revocable premium trust belonged to its employee medical plan. EBSA said the separate policy trust and insurance policy were plan assets, but the…

Advisory Opinion 1993-14A Opinion Letter May 5, 1993
CA

Help-wanted ads during a strike must explicitly disclose the labor dispute, Labor Code section 973

DLSE wrote to an employer engaged in an active strike after its newspaper help-wanted advertisement for maintenance mechanics, a position covered by the expired collective bargaining agreement,…

1993.05.04-2 Opinion Letter May 4, 1993
CA

A short plant shutdown of 10 days or less with a set return date is not a termination requiring final-wage payment

An attorney asked DLSE how planned short-duration facility shutdowns (about a week each) would affect an employer's final-wage obligations under the Labor Code. DLSE explained its long-standing…

1993.05.04 Opinion Letter May 4, 1993
US

Disposal of toenail debris in podiatry practices

A podiatrist asked whether toenail particles and dust required regulated waste disposal. OSHA said particles are potentially infectious only if contaminated with blood or other specified material.…

1993-04-30-0 Opinion Letter April 30, 1993
US

Disinfectant exposure and bloodborne pathogen duties

A dental safety consultant raised concern that increased disinfectant use could expose workers to chemicals. OSHA said the bloodborne pathogens standard required suitable decontamination and that…

1993-04-30 Opinion Letter April 30, 1993
US

Affiliated mutual fund fees under PTE 77-4 Unknown

A trust company asked whether its plans could invest in affiliated mutual funds under a prohibited transaction exemption. EBSA said the described waiver of investment advisory fees could satisfy the…

Advisory Opinion 1993-13A Opinion Letter April 27, 1993
US

PNC affiliated funds and service fees under PTE 77-4 Unknown

A financial group asked whether plans it managed could buy affiliated mutual fund shares while its affiliates received fees for additional services. EBSA said the exemption did not require crediting…

Advisory Opinion 1993-12A Opinion Letter April 27, 1993
US

Optional unemployment denials for school employees between terms Unknown

ETA revised its interpretation of optional unemployment benefit denials for school employees between academic terms and during breaks. It said states may limit a denial to selected classes of…

UIPL No. 43-93 Guidance April 23, 1993
US

Wood dust sampling and cyclone use

A public health researcher questioned a sampling instruction for wood dust. OSHA said the reference to respirable sampling was a typographical error, corrected its information system, and added a…

1993-04-22 Opinion Letter April 22, 1993
US

Disaster unemployment benefit amounts for April–June 1993 Unknown

ETA directed state unemployment agencies to use the attached average weekly benefit amounts when calculating disaster unemployment assistance for disasters occurring April through June 1993. States…

UIPL No. 22-93 Guidance April 19, 1993
CA

A temporary-help firm employing garment workers must register as a garment manufacturer

A Florida-based staffing company asked DLSE why it would need to register as a garment manufacturer if it merely employs and supplies workers to perform garment-industry services for clients. DLSE…

1993.04.19-3 Opinion Letter April 19, 1993
CA

DLSE will keep enforcing the Wage Orders' gross-negligence wage deduction, but warns it may be void as against public policy

An employer's HR representative asked DLSE to define "simple" versus "gross" negligence for purposes of deducting the cost of lost or damaged equipment from an employee's final paycheck, and whether…

1993.04.19-1 Opinion Letter April 19, 1993
CA

A flat 1/24th-of-annual-salary payday schedule doesn't satisfy Labor Code section 204's pay-period timing rules

A law firm asked whether an employer could pay both exempt and non-exempt salaried employees exactly 1/24th of their annual salary on the 15th and last day of each month, regardless of the actual…

1993.04.19 Opinion Letter April 19, 1993
US

Fire extinguishers and toeboards in home construction

A home builder proposed keeping fire extinguishers in crew trucks and using a low wall plate as a toeboard. OSHA said truck extinguishers did not meet its concern because workers reaching the truck…

1993-04-19-2 Opinion Letter April 19, 1993
US

Blood product labeling exemption for diagnostic kits

A diagnostics company asked whether its FDA-reviewed blood product labels satisfied an OSHA exception. OSHA said the described labels appeared to meet the exception, while employees handling the…

1993-04-19-0 Opinion Letter April 19, 1993
US

Contaminated uniforms under the bloodborne pathogens standard

A police association asked who must clean contaminated uniforms. OSHA said federal OSHA lacked jurisdiction over local and state police, then explained its private sector rule: a uniform functioning…

1993-04-19 Opinion Letter April 19, 1993
US

Emergency response training for marine oil spill cleanup

An oil company asked whether its trained hazardous materials technicians could clean up a marine oil spill during emergency response. OSHA said they could if they were its own initial responders,…

1993-04-16 Opinion Letter April 16, 1993
US

Interim confined space enforcement for utility underground work Unknown

An internal OSHA memo addressed permit required confined space enforcement in utility manholes and vaults. It directed staff to consult a deputy director before citing these facilities while the…

1993-04-15-0 Guidance April 15, 1993
US

Guarding tabletop centrifuges Unknown

A device maker asked whether machine guarding provisions applied to tabletop centrifuges. OSHA said a specific rotating barrel provision did not apply, but the general guarding rule covered hazards…

1993-04-15 Opinion Letter April 15, 1993
US

Policy framework for the 1993 Summer Challenge youth program Rescinded

ETA set out a provisional framework for the proposed 1993 Summer Challenge program for economically disadvantaged youth. It addressed supervised work, academic enrichment, program oversight, data…

TEGL No. 9-92 Guidance April 14, 1993
US

Process safety threshold for listed chemicals and compounds Unknown

An environmental services firm asked when listed chemicals and compounds trigger process safety management. OSHA said Appendix A thresholds applied to pure listed chemicals unless the entry…

1993-04-14-3 Opinion Letter April 14, 1993
US

Radiofrequency protective clothing performance criteria

The FCC asked OSHA about radiofrequency protective clothing. OSHA said effective use depends on breakdown threshold, surface heating, absorption reduction, maintainability, and complete body…

1993-04-14-2 Opinion Letter April 14, 1993
US

Hydrogen sulfide respiratory protection during tank gauging

A motor carrier association asked about hydrogen sulfide exposure at crude oil tank hatches. OSHA said employers needed exposure determinations for the work and, for sour crude gauging, monitoring…

1993-04-14-0 Opinion Letter April 14, 1993
US

Human albumin under the bloodborne pathogens standard

A manufacturer asked OSHA to exclude heat-treated human albumin from its bloodborne pathogens standard. OSHA declined because the product remained within the standard’s definition of blood. It…

1993-04-13 Opinion Letter April 13, 1993
US

Grounding continuity and extension cord indicator lights

A seller asked whether a built-in light on an extension cord satisfied continuity testing. OSHA said the light showed the cord was energized but gave no information about the continuity of its…

1993-04-08 Opinion Letter April 8, 1993
US

Michigan builders health plan fully insured under proposed contract Unknown

A requester asked whether a proposed insurance agreement would make a Michigan builders' health program fully insured. EBSA said yes, if executed as described: the insurer would owe all covered…

Advisory Opinion 1993-11A Opinion Letter April 5, 1993
US

Proper recording of a hepatitis A exposure for OSHA injury and illness recordkeeping purposes Unknown

An employer asked how to record employees’ possible hepatitis A exposure. OSHA said an exposure alone is not recordable unless an employee develops an infection or disease; preventive care by itself…

1993-04-02-0 Opinion Letter April 2, 1993
US

Frame grounding of arc welding machines

An engineering company asked how OSHA’s construction rules apply to frame grounding on portable, engine-driven arc welding machines. OSHA said the machines are basically portable generators and that…

1993-04-02 Opinion Letter April 2, 1993
US

Recording cases on the OSHA log that involve bloodborne pathogens Unknown

OSHA told regional recordkeeping coordinators that an exposure incident involving blood or other potentially infectious material may be recordable under 29 CFR Part 1904. Contact with intact skin…

1993-04-01-0 Opinion Letter April 1, 1993
US

Meeting labeling requirements of the hazard communication standard for slag wool

A slag wool manufacturer asked whether it could use signs and shipment documents instead of attaching labels directly to bales. OSHA agreed that the proposed methods could meet the Hazard…

1993-04-01 Opinion Letter April 1, 1993
CA

On-call beeper time may be compensable when employer control is unreasonable under California's fact-specific test

A law firm representing a rural hospital asked DLSE to clarify when beeper-based on-call time, where employees must respond within 20 minutes but are not required to stay on the premises, counts as…

1993.03.31 Opinion Letter March 31, 1993

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