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.
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Format Used for the Exchange of UCX/UCFE Claims Control Data Between State Employment Security Agencies (SESAs) and the Louisiana UCX/UCFE Claims Control Center (LCCC) Unknown
ETA instructed state unemployment agencies how to format, transmit, and cancel claims-control inquiries for former service members and federal civilian employees. Its attachments define the…
Bloodborne pathogens requirements for emergency medical services Unknown
A member of Congress asked OSHA about bloodborne-pathogens requirements affecting emergency medical services. OSHA said diluted household bleach could be used for specified decontamination,…
Bloodborne pathogen exposure for first aid, cleanup, and hotel housekeeping
A compliance provider asked how OSHA's bloodborne pathogens rule applies to first aiders, cleanup crews and hotel housekeepers. OSHA said workers expected to provide first aid or clean contaminated…
Agreements between the State Employment Security Agencies (SESA) and the Department of Health and Human Services' Office of Child Support Enforcement (OCSE) Implementing the Requirements of Section 303(h)(1) of the Social Security Act (SSA) Unknown
ETA told state unemployment agencies that federal child support officials wanted to update their data-sharing agreements. It identified proposed changes to the transfer method, frequency, and volume…
Pentane storage and solvent blending under the Process Safety Management rule Unknown
A requester asked whether large pentane storage and a solvent blending setup were exempt from OSHA’s Process Safety Management rule. OSHA did not decide either question on the facts supplied. It…
Quality Appraisal Issues: Questions and Answers--Nonmonetary Determinations Promptness, and Emergency Unemployment Compensation Unknown
ETA answered state agency questions about when the timeliness clock begins for nonmonetary claim determinations and said Emergency Unemployment Compensation cases should not be used for regular UI…
Process Safety Management coverage of paint manufacturing and blending Unknown
A paint industry association asked whether mixing and blending flammable liquids below their boiling points was exempt from the PSM rule. OSHA said the storage and transfer exemption did not cover a…
Withdrawal of UCX and UCFE claims and assignment of federal wages
ETA told state unemployment agencies to apply state rules that permit withdrawal of a regular unemployment claim to claims by former service members and federal civilian employees. Withdrawing the…
California workers compensation enforcement and ERISA Unknown
California officials asked whether ERISA blocked enforcement of workers’ compensation requirements against an employee leasing arrangement. EBSA said the state could require a separate workers’…
Bank financial statements for a plan repurchase agreement Unknown
A health plan asked whether its bank counterparty could use parent-company financial statements and the bank's Call Report for a repurchase agreement exemption. The bank did not maintain separate…
State UI benefit averages used for 1992 disaster assistance Unknown
ETA directed state unemployment agencies to use the attached state average weekly unemployment insurance benefit amounts for disasters occurring October through December 1992. It explained that the…
Hazard communication for PCB-containing light ballasts
A company asked how OSHA's hazard communication standard applies to workers who make, remove or dispose of light ballasts containing PCBs. OSHA said encased PCBs that pose no exposure threat do not…
Implementation of bloodborne pathogens and hazardous waste emergency rules
A member of Congress asked OSHA to postpone its bloodborne pathogens and hazardous waste emergency response rules because of compliance costs. OSHA declined, saying both standards were already in…
First aid response time and near proximity requirements Unknown
An employer asked what “in near proximity” means for first aid under 29 CFR 1910.151(b). OSHA said first aid should be available within three to four minutes where life-threatening injuries are…
Lockout training video review and employer program duties Unknown
A manufacturer asked OSHA to confirm that its lockout training video complied with the hazardous-energy rule. OSHA declined to certify a video outside a specific workplace. It said employers must…
End of routine tenth-letter inspections after non-formal complaints Unknown
OSHA told regional administrators to stop automatically inspecting every tenth employer that gave a satisfactory response to a non-formal complaint. It kept the policy of inspecting when an employer…
Guarding rotary knives used in poultry processing
An OSHA regional office asked how to cite unguarded rotary knives in poultry processing. OSHA said it would not cite the absence of a front flapper guard because it had found that device did not…
Glove use, hepatitis B vaccination costs, and bloodborne pathogen trainers
A correspondent asked about gloves during injections, payment for hepatitis B vaccination, and who can train dental office workers. OSHA said glove use turns on reasonably anticipated contact with…
Counting restricted or lost workdays during personal leave Unknown
An employer asked whether personal medical or pregnancy leave interrupted the count of restricted or lost workdays after a work injury. OSHA said days on leave arranged before the injury were…
Injury log for an employee hurt at another company facility Unknown
An occupational health nurse asked which company facility should record an injury during an employee's temporary training assignment. OSHA said a recordable case belonged on the log of the…
Recordkeeping exemption for employers with ten or fewer employees Unknown
A hospice asked whether its size excused it from OSHA injury and illness logs. OSHA said employers with no more than ten employees during the previous year normally did not have to keep those…
Payment of Interest on Title XII Loans Unknown
ETA instructed states on paying interest owed on federal Title XII unemployment loans, including calculation and billing timing, allowable funding sources, and notice of the source of payment. It…
State plan inspection staffing for process safety management Unknown
OSHA answered Maryland's questions about process safety inspections under its then-current directive. It said federal OSHA could supply an experienced team leader for certain state inspections, that…
Toe clearance for a hanging manhole ladder Unknown
A manufacturer asked whether a hanging manhole ladder design met an exception in a proposed walking surfaces rule. OSHA said its then-current standards had no provision for that design and discussed…
Combined claims accounts and small plan annual reporting Unknown
A benefits consultant asked whether small employer welfare plans paying claims through a shared administrator account could skip annual reports. EBSA said the exemption for benefits paid from…
Carcinogen disclosure for acetaldehyde under hazard communication
A member of Congress asked how to reconcile carcinogen classifications for acetaldehyde with an FDA finding that it was safe for use as a flavoring. OSHA said chemical makers and importers had to…
Unemployment Insurance Revenue Quality Control -- Transition to Mandatory Implementation Unknown
ETA announced a transition period beginning January 1993 to prepare state agencies for Revenue Quality Control reviews of unemployment tax operations. It described staffing, sampling, systems…
Bloodborne pathogen rule and construction work
A worker asked whether OSHA's bloodborne pathogens standard applied to construction. OSHA said it did not apply to construction work as defined in the cited rule, but could apply to covered…
A garment shop using an unlicensed staffing firm is deemed an employer and needs its own workers' compensation coverage
A garment shop asked DLSE about California's workers' compensation coverage requirements after submitting an insurance binder naming a staffing company, Creative Staff Management, Inc., as the…
Ground fault protection on construction extension cords and portable tools
A contractor asked whether ground fault circuit interrupters on cords and portable tools eliminate the need for an assured equipment grounding conductor program. OSHA said fully approved GFCI…
Bloodborne pathogen rule for allergists and needle removal
An OSHA regional administrator asked whether allergists doing skin tests were covered by the bloodborne pathogens rule and could remove needles by hand. OSHA said the tests reasonably anticipated…
Laundering personal clothing contaminated with blood
A physician asked whether an employer had to launder an employee's personal clothes after contamination with blood or other potentially infectious material. OSHA said the standard expressly covered…
Hazard communication exemption for regulated hazardous waste
A chemical manufacturer asked which waste containers were exempt from the hazard communication rule. OSHA said a container must meet the cited hazardous waste requirements, including applicable…
Recording lost days, vaccine reactions and medical treatment Unknown
A state labor official asked six questions about OSHA injury and illness logs. OSHA explained how a resignation tied to an injury affected estimated lost days, when a later injury became a new case,…
Enforcing temporary labor camp housing standards
The Wage and Hour Division asked how OSHA's temporary labor camp standard should be enforced at short-term tent and trailer sites. OSHA said safety and health conditions such as shelter, water,…
Process safety coverage of natural gas pipelines Unknown
A gas industry association asked whether OSHA's process safety rule applied to natural gas transmission and distribution facilities. OSHA said federal pipeline safety regulations then addressed the…
Employer share of split-dollar life policy value Unknown
A broker asked whether the cash value in a proposed split-dollar life policy funding employee death benefits belonged to the ERISA plan. EBSA said the employer retained that value and the plan had…
Using ANSI standards under OSHA's general duty clause Unknown
A platform manufacturer asked about OSHA's use of ANSI standards while a fall protection rule was under development. OSHA said it could cite consensus standards as evidence of recognized industry…
Stairway rules for scaffold step unit towers
A scaffold maker asked whether OSHA's construction stairway rules applied to scaffold step unit towers. OSHA said those rules applied when the towers provided access somewhere other than a scaffold…
Hazardous substance response training for hospital staff
A physician asked what training hospital employees needed when receiving contaminated emergency patients. OSHA said personnel expected to decontaminate victims needed first responder operations…
HAZWOPER training at voluntary cleanup sites
A utility asked whether its voluntary cleanup sites and employees who did not perform cleanup fell under HAZWOPER. OSHA said a state consent order recognized the sites for purposes of the rule, even…
Sharps containers for self-sheathing needles Unknown
A medical device company asked OSHA to allow used self-sheathing needles in ordinary municipal waste. OSHA said states controlled the final disposal method, but its workplace safety rule still…
Bloodborne pathogen rule and health care inspection priorities Unknown
A senator asked about the bloodborne pathogens rule's effect on health care employers and OSHA's inspection plans. OSHA said employers had to protect workers against occupational exposure and…
Use of elbow splints under a meatpacking ergonomics settlement Unknown
An OSHA regional office asked how a specific meatpacking company's ergonomics settlement treated elbow splints. OSHA said an authorized treating physician who knew the company's program had to…
Retail facility exemption under the process safety rule Unknown
A company asked whether its sales to end users made it a retail facility exempt from the process safety management rule. OSHA said the information supplied did not establish a company-wide…
Bloodborne pathogen coverage for electric cooperative first aid
An attorney asked whether electric cooperative field crews were covered by OSHA's bloodborne pathogens standard. OSHA said workers designated to give first aid could reasonably anticipate exposure…
Emergency Unemployment Compensation (EUC) Optional Initial Claims Unknown
ETA explained how state unemployment agencies should count initial claims when people could choose Emergency Unemployment Compensation instead of a new regular unemployment claim. Its examples…
DOT infectious substance labels on medical waste containers Unknown
A waste industry group asked whether DOT infectious substance labels could replace OSHA biohazard labels on outer containers during transport. OSHA said it would accept DOT labels where DOT required…
Bloodborne pathogen rule for drilling crew first aid
A drilling company asked whether the bloodborne pathogens standard covered supervisors trained in first aid and CPR. OSHA said coverage turned on reasonably anticipated contact with blood during…
Disinfectant standard for dental work surfaces Unknown
A product maker asked whether its disinfectant met OSHA's criteria for cleaning blood-contaminated work surfaces in dental facilities. OSHA said its then-current enforcement policy treated…
Hospital hazardous release response and HAZWOPER training
A hospital council asked when a spill counted as an emergency under HAZWOPER and what staff training was required. OSHA said the distinction depended on hazard and response conditions, not just…
Directed trustee purchases of bank parent stock Unknown
A bank serving as directed trustee asked whether client plans could buy its parent company’s stock through unrelated brokers. EBSA said blind exchange trades ordered by an unaffiliated named…
Employee access to OSHA injury and illness logs Unknown
An employee asked about access to injury records and whether an earlier workplace injury should have appeared on an OSHA log. OSHA said employees and former employees could inspect the log for an…
Pooled reinsurance health program as a MEWA Unknown
A requester asked whether an administrator's supposedly separate employer health programs were one multiple employer welfare arrangement. EBSA said pooled reinsurance payments and benefit claims…
Recording hearing loss, burns and falls on injury logs Unknown
A company physician asked when hearing loss, burns and falls were recordable. OSHA described a work-relatedness presumption for hearing loss after workplace noise exposure and the evidence needed to…
Consumer product use under hazard communication in a medical office Unknown
A physician questioned OSHA's bloodborne pathogen and hazard communication requirements for medical offices. OSHA said a consumer cleaning product could fall under hazard communication when…
Exposure control plans and protective equipment in medical offices
A senator relayed a physician's concerns about the bloodborne pathogens rule. OSHA said an exposure control plan need not be lengthy or professionally produced, but must contain the elements…
Changes in Reporting Unemployment Compensation Benefit Payments--Department of Commerce and Bureau of the Census Unknown
ETA directed state agencies to report unemployment benefit payments for former Census employees made after September 30, 1992 under the Department of Commerce agency code, while retaining the Census…
Twenty injury and illness recordkeeping questions Unknown
A safety consultant asked twenty questions about recording workplace illnesses and injuries, including chemical exposure, stress, off-duty time and first aid. OSHA gave case-specific answers under…
OSHA's worker safety jurisdiction over bungee jumping Unknown
A bungee jumping operator asked about OSHA policy for the activity. OSHA said its statutory concern was worker safety, while customer and bystander safety belonged to state and local authorities. It…
How this guidance is useful
- See how the agency reads the law: An opinion letter shows how a state labor agency actually applied wage-and-hour law to a real employer's or worker's situation.
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This library covers 8 states plus federal guidance so far. Every document is checked against the agency's official source before it is published, so states are added as their labor departments' guidance is verified, not all at once. If your state is not listed yet, its labor department's own site is the place to check.