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June 19, 1997

Sherry Maddox
Manager, Clinical Risk
Humana Inc.
500 West Main
Post Office Box 1438
Louisville, KY 40201-1438

Dear Ms. Maddox:

Thank you for your letter, which we received on May 28, 1997, requesting clarification on Humana Inc.'s recordkeeping obligations.

Your Standard Industrial Classification code, SIC 80, classifies you primarily under health services (HMOs, PPOs, hospitals). Please note that in the reference which you cited on Page 5 of the Recordkeeping Guidelines concerning employees in low-hazard industries (insurance), it also states, "An employer whose establishment is classified in SIC's 52-89, (excluding 52-54, 70,75, 76, 79, and 80) need not comply...." (emphasis added). Therefore, the health services industry is not an exempted industry and you fall under the OSHA injury and illness recordkeeping regulation.

To help you understand the reason you are required to continue recordkeeping in the various situations you have described, I am enclosing an attachment on auxiliary establishments found in the SIC Manual. As described, these are all treated as operating establishments and continue to fall under OSHA recordkeeping regulation.

I hope you find this information useful. If you have any further questions, please do not hesitate to contact us.

Sincerely,

Bob Whitmore
Chief
Division of Recordkeeping Requirements