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January 26, 1993

Mr. Brad Brown
Planning & Research Associate II
Department of Labor
Bureau of Labor Standards
Research & Statistics Division
State House Station #45
Augusta, Maine 04333-0045

Dear Brad:

Thank you for your letter dated January 12, requesting an interpretation concerning OSHA recordkeeping requirements as applied to sheltered workshops.

As mentioned in your letter, the Standard Industrial Classification for sheltered workshops is 8331, no matter what specific activity they perform. As found on page 5 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, SIC 8331 is an exempt industry. Therefore sheltered workshops need not keep OSHA injury and illness records unless contacted by the Bureau of Labor Statistics to participate in their Annual Survey.

Care must be taken when assigning SIC code 8331. It must be established that the primary function of the company is to provide job training and vocational rehabilitation, and not the manufacture of a product.

I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.

Sincerely,



Stephen A. Newell
Director
Office of Statistics