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August 31, 1993

Mr. Larry S. Valentine
Director of Loss Prevention
Pet Incorporated
400 South 4th Street
St. Louis, Missouri 63102

Dear Mr. Valentine:

Thank you for your letter dated July 7, requesting interpretations on two OSHA injury and illness recordkeeping issues. Your procedure for maintaining and retaining the OSHA Log, as described in your letter, complies with the recordkeeping regulations. Furthermore, employers are allowed to keep as many sets of records as they feel necessary, as long as the most current set of OSHA records are produced upon a request of access to the records by an authorized person.

Your method of entering "Occupation" and "Department" for floating employees is also within compliance of the recordkeeping regulations. The more precise the information, the more useful the records will be for evaluating the safety and health environment of your establishment.

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

Sincerely,



Stephen A. Newell Director
Office of Statistics