OSHA Instruction CPL 2.115
June 14, 1996
Directorate of Compliance Programs


SUBJECT:  Complaint Policies and Procedures

A. Purpose.  This instruction establishes revised policies and
   procedures for handling complaints relating to workplace safety
   and health conditions.

B. Scope.  This instruction applies OSHA-wide.  States with
   OSHA-approved state plans are encouraged to adopt similar policies
   but may choose to experiment with other alternatives.  See
   paragraph H., below.

C. References.

   1.   OSHA Instruction CPL 2.103, September 26, 1994, Field
        Inspection Reference Manual (FIRM).

   2.   OSHA Instruction FAP 1.3, May 17, 1996, Federal Agency
        Safety and Health Programs.

   3.   OSHA Instruction STP 2.22A, May 14, 1986, State Plan
        Policies and Procedures Manual (SPM).

   4.   OSHA Instruction ADM 1-1.31, September 20, 1993, The IMIS
        Enforcement Data Processing Manual

D. Action.  OSHA Regional Administrators and Area Directors shall
   ensure that the guidelines and procedures set forth in this
   instruction are followed.  This instruction supersedes certain
   provisions of the Field Inspection Reference Manual (FIRM)
   contained at Chapter I, C.  The FIRM shall be revised to
   incorporate these changes.  Also, see FAP 1.3 for instructions on
   handling complaints lodged against Federal Agencies.

E. Summary of Changes.  Significant features of the new policy are:

   1.   Complaints are no longer identified as "formal" or
        "nonformal."

   2.   Based on new criteria, complaints shall now be classified as
        those that result in onsite inspections and those that
        result in investigations using telephone and telefax, and
        similar means.

   Appendix A contains a flow chart graphically depicting a summary
   of this new complaint policy.

F. Application.  This instruction applies to complaints received
   addressing hazards in all covered workplaces, including private
   sector and Federal Agencies.  A complaint lodged against a Federal
   Agency can also include an alleged violation of 29 CFR Part 1960,
   Basic Program Elements for Federal Employee Occupational Safety
   and Health Programs and Related Matters.

G. Background.  The new complaint policies and procedures were
   developed through the Complaint Process Improvement Project as a
   part of the Department of Labor/OSHA's Reinvention Effort.  They
   were pilot-tested in the Area Offices in Cleveland, Ohio, and
   Peoria, Illinois.  After review and evaluation of the pilot test,
   the policies and procedures are being implemented as part of
   OSHA's national program.

   These new procedures will provide quicker resolution of
   complaints, speed hazard abatement and enable OSHA to focus OSHA's
   inspection resources on the workplaces where they are most needed.

   This new policy continues to assure the right of current employees
   and their representatives to an onsite inspection; it also
   encourages them to attempt resolution of lower priority complaints
   in a more expeditious manner.

H. Federal Program Change.  This is a Federal Program Change that
   impacts State programs.

   1.   The Regional Administrator shall ensure that this change is
        promptly forwarded to each State designee, using a format
        consistent with the Plan Change Two-Way Memorandum in
        Appendix P, OSHA Instruction STP 2.22A, State Plan Policies
        and Procedures Manual.

   2.   The Regional Administrator shall explain the content of this
        change to the State designee.

   3.   States are encouraged, but not required, to adopt an
        identical or alternative policy.  States shall be asked to
        provide preliminary notification to the RA within 30 days
        from the date of this introduction of their intent to adopt
        or not to adopt the procedures in this directive.  The State
        shall formally respond to this change with an indication of
        their intent within 70 days in accordance with paragraph
        I.1.a.(2)(a) and (b), Chapter III or Part I of the SPM.  If
        the State adopts identical procedures, no further plan
        change supplement need be submitted.  If the State adopts
        different compliance procedures, a copy of the procedures
        shall be provided to the Regional Administrator within six
        months from the date of this directive for review.

   4.   State designees may also wish to include alternative
        procedures in a pilot Performance Agreement to be negotiated
        between the State and the RA and approved by the Assistant
        Secretary.  Such agreements shall define interim indicators
        of effectiveness and the results anticipated from the
        successful policy.

   5.   The Regional Administrator shall review policies,
        procedures, and instructions issued by the State and monitor
        their implementation as provided in a Performance Agreement
        or through routine monitoring focussing on impact and
        results.

I. Definitions.

   1.   Complaint  Notice of an alleged hazard (over which OSHA has
        jurisdiction), or a violation of the Act, alleged by a past
        or present employee, a representative of employees, an 11(c)
        officer seeking resolution of a discrimination complaint or
        any other individual knowledgeable of the alleged hazardous
        condition.

   2.   Referral  Notice of an alleged hazard or violation of the
        Act given by any source not listed in Section I.1 above,
        including CSHO referrals.  See Chapter 1, Section C-10 of
        the FIRM for procedures to be followed for referrals.

   3.   Permanently disabling injuries or illnesses  Injuries or
        illnesses which may result in permanent disabilities or
        illnesses that are chronic or irreversible.  Examples of
        permanently disabling injuries or illnesses include:
        amputation, blindness, standard threshold shift in hearing,
        lead or mercury poisoning, or third-degree burns.

   4.   Complaint Inspection:  A complaint inspection is an
        inspection that is initiated primarily as a result of a
        complaint, is conducted by an OSHA compliance officer at the
        employer's worksite, and that meets at least one of the
        criteria listed below:

        a.  The complaint was reduced to writing, is signed by a
        current employee or employee representative,and states the
        reason for the inspection request with reasonable
        particularity.  In addition, there are reasonable grounds to
        believe that a violation of a safety or health standard or
        danger exists, as provided in Section 8(f)(1) of the Act.

        b.  The complaint alleges that physical harm, such as
        disabling injuries or illnesses (as defined in I.3. above)
        has occurred as a result of the complained-of hazard(s) and
        there is reason to believe that the hazard or related
        hazards still exist.

        c.  The complaint is based on an allegation of an imminent
        danger situation (See the FIRM for additional procedures to
        be followed).

        d.  The complaint identifies an establishment or an alleged
        hazard covered by a local or national emphasis program.

        e.  The employer fails to provide an adequate response to a
        complaint as described in Section L, below, or the
        complainant provides evidence that the employer's response
        is false or does not adequately address the hazard(s).

        f.  The firm or establishment that is the subject of the
        complaint has a history of egregious, willful, or
        failure-to-abate citations, within Area Office jurisdiction
        and within the last three (3) years.  The Area Director may
        determine not to inspect a facility when good quality
        abatement evidence has been provided and programs have been
        implemented to prevent a recurrence of hazards.

        g.  An 11(c) discrimination investigator requests that a
        complaint inspection be conducted in response to an
        employee's allegation that he/she was discriminated against
        for complaining about safety or health conditions in the
        workplace or for refusing to do an allegedly imminently
        dangerous job/task.

        h.  If an inspection is scheduled, or has begun, at an
        establishment, and a complaint that would normally be
        investigated by telephone/fax is received, that complaint
        may, at the Area Director's discretion, be scheduled for
        inspection as a companion complaint.

   5.   Complaint Investigation:  A complaint investigation is
        conducted for other complaints that do not meet one of the
        above complaint inspection criteria.  It does not include an
        on-site inspection of the workplace.

        An "investigation" differs from an "inspection" in that in
        an investigation, OSHA advises the employer of the alleged
        hazards by telephone and telefax, or by letter if necessary
        (e-mail may be available in the future).  The employer is
        required to provide a written response.  OSHA shall provide
        copies of the response(s) to the complainant.

J. Procedures for Receiving a Complaint by Telephone.

   1.   During the course of telephone contact with the complainant,
        the following general guidance shall be followed.  Detailed
        optional guidance is found in Appendix B.  The person taking
        the complaint must, to the extent feasible:

        a.  determine if the complainant is a current employee or an
        employee representative;

        b.  explain the complaint process, and if appropriate, the
        concepts of "investigation" and "inspection", as well as the
        relative advantages of each;

        c.  determine the exact nature of the alleged hazard and the
        basis of the complainant's knowledge;

        d.  determine if complaint items are apparent violations of
        OSHA standards or the OSH Act;

        e.  inform the complainant(s) of their rights to
        confidentiality in accordance with Section 8(f)(1) of the
        Act, and ask whether they wish to exercise that right;

        f.  explain 11(c) rights to private sector employees or
        reprisal and discrimination protection provided by Executive
        Order 12196, 29 CFR Part 1960.46 and the Whistleblowers
        Protection Act of 1989 to Federal employees.  (See FAP 1.3
        for reports of reprisal or discrimination from Federal
        employees).

K. Procedures for an Inspection

   1.   The Area Office supervisor shall evaluate each complaint,
        and other available information, and exercise professional
        judgement to decide whether or not there are reasonable
        grounds to believe that a violation or hazard exists.  If
        there are not reasonable grounds to believe that a violation
        or hazard exists, an inspection shall not be conducted.  The
        Area Director may also determine not to inspect a facility
        if she/he has evidence that the condition complained of is
        being abated.

   2.   If the complaint meets at least one of the inspection
        criteria listed in I.4. above, the complainant or employee
        representative shall be informed that an inspection will be
        scheduled and that he/she shall be advised of the results.
        After an inspection, the Area Office shall send the
        complainant a letter addressing each complaint item, with
        reference to the citation(s) or a sufficiently detailed
        description of why the findings did not result in a
        violation.

   3.   If the employee or employee representative requests an
        on-site inspection, but has not submitted a signed complaint
        or one which meets any of the other inspection criteria,
        he/she shall be advised that OSHA will hold the complaint
        for five working days so that he/she can either come into
        the office and sign the complaint or mail/fax a signed
        complaint letter to OSHA.  If a signed complaint is not then
        received after five working days, or if the complainant does
        not initially request an on-site inspection, OSHA will
        proceed with the investigation process.  OSHA will no longer
        mail OSHA-7 complaint forms to the complainant for
        signature.

   4.   When a written complaint signed by a current employee or
        employee representative is received, and there are
        reasonable grounds to believe that a violation or hazard
        exists, an inspection shall be conducted.  The complainant
        may be contacted for clarification of issues raised in the
        complaint, as necessary.  Where a written, signed complaint
        has been submitted, but, in the professional judgement of
        the Area Director, there are no reasonable grounds to
        believe that a violation or danger exists, no inspection or
        investigation shall be made.  In such situations, the
        complainant shall be notified in writing of OSHA's intent to
        not conduct an investigation or inspection, the reasoning
        behind such a determination, and the appeal rights provided
        under 29 CFR 1903.12.

L. Procedures for an Investigation

   1.   If the complaint requires an investigation, OSHA shall
        contact the employer by telephone and notify him/her of the
        complaint and its allegation(s).  The employer shall be
        advised that he/she must investigate and determine whether
        the complaint is valid.  The employer shall be advised that
        a response is due within five(5) working days and that OSHA
        requests the posting/sharing of information with employees,
        employee representative and/or the safety committee.
        Although the employer must respond within the above time
        frame, he/she may not be able to complete abatement action,
        but is encouraged to do so.  See the letter to employers at
        Appendix C, pages 1-2 for what is required in their
        response.

   2.   OSHA shall ask for the name of the contact person at the
        employer's worksite and may also request the name, address
        and telephone number of the union and/or employee
        representative, if any.  The company fax number is also
        requested.  The employer is advised of what information is
        needed to answer the complaint.  The employer is encouraged
        to respond by fax.  In addition, documentation, such as
        invoices, sampling results, photos, video tape, etc., shall
        be required and provided by the employer as evidence of
        abatement, to ensure that the complaint hazard(s) has been
        eliminated.

   3.   As soon as possible thereafter, the notification letter
        shall be faxed (or mailed, where no fax is available) to the
        employer.

   4.   The complainant shall be advised of the employer's
        response(s).  The complainant shall be advised of his/her
        rights to dispute the employer's response, and of the right
        to request an inspection if the alleged hazard persists.
        The employee need not put his/her dispute with the
        employer's response in writing.  Disputed issues may be
        clarified by telephone, and some discretion is allowed in
        situations where, in the professional judgement of the Area
        Director, the complaint does not warrant an on-site
        inspection.  In such situations, the complainant shall be
        notified of OSHA's intent not to conduct an inspection, an
        the reasoning behind such a determination.  If the employee
        disagreement takes the form of written complaint, refer to
        procedures at K.3 above.

   5.   If a signed complaint is received after the complaint
        investigation process has begun (for example, the signed
        complaint is received on the 8th day), OSHA shall make a
        determination as to whether the alleged hazard is still
        likely to exist based on the employer's response and by
        contacting the complainant.  The complainant shall be
        informed that the complaint investigation has begun and
        he/she still retains the right to request an on-site
        inspection if he/she disputes the results and believes the
        hazard still exists.

   6.   When OSHA receives an adequate response from the employer,
        and the complainant does not dispute or object to the
        response, an on-site inspection normally will not be
        conducted.

   7.   If no employer or an inadequate employer response is
        received after the allotted five (5) working days, an
        additional contact with the employer may be made before an
        inspection is scheduled.  Ultimately, if the employer
        provides no response or an inadequate response or OSHA
        determines from other information that the condition is not
        being corrected, an inspection will be scheduled.

   8.   The complaint shall not be closed until OSHA is certain that
        the hazard has been eliminated/abated.

M. Identity of Complainant.  The identity of the complainant shall be
   withheld from the employer, upon the request of the complainant,
   in accordance with Section 8(f)(1) of the Act.  No information
   shall be given to employers which would allow them to identify the
   complainant.

N. Sample letters for new complaint procedures.  Appendix C contains
   samples of notification letters to the employer and complainant, a
   certification of posting letter, and a complaint form letter to an
   employer closing the complaint.

O. Recording in IMIS.  Information about complaint inspections or
   investigations shall be recorded in IMIS following current
   instructions given in the IMIS manual.  Refer to Appendix D of
   this instruction for additional guidance.


Joseph A. Dear
Assistant Secretary

DISTRIBUTION:  National, Regional, and Area Offices
               All Compliance Officers
               State Designees
               NIOSH Regional Program Directors
               7(c)(1) Project Managers

(For Appendix A, Click Here) APPENDIX B OPTIONAL INFORMATION TO BE OBTAINED Obtain information from the caller by asking the following questions, where relevant; For all complaints: What is the hazard? _________________________________________________ How are workers exposed to this hazard? Describe the unsafe or unhealthful conditions; identify the location. ______________________ _____________________________________________________________________ What work is done in the unsafe/unhealthful area? Identify, as well as possible, the type and condition of equipment in use, the materials (i.e. chemicals) being used, the process/operation involved, and the kinds of work being done near the hazardous area. Have there been any recent chemical spills, releases, or accidents? _____________________ _____________________________________________________________________ _____________________________________________________________________ With what frequency are workers doing the task which leads to the exposure? Continuously? Every day? Every week? Rarely? For how long at one time? How long has the condition existed as far as can be determined? Has it been brought to the employer's attention? Have any attempts been made to correct the condition, and if so, who took these actions? What were the results? _____________________________________ _____________________________________________________________________ _____________________________________________________________________ _____________________________________________________________________ How many shifts are there? What time do they start? On which shift does the hazardous condition exist? _________________________________ _____________________________________________________________________ What personal protective equipment (i.e., hearing protection or respirators) is required by the company relevant to the alleged exposure? Is it used by employees? Include all PPE and describe it as specifically as possible. Include the manufacturer's name and any identifying numbers. ________________________________________________ _____________________________________________________________________ How many people work in the establishment? How many are exposed to the hazardous conditions? How near do they get to the hazard? _____________________________________________________________________ _____________________________________________________________________ Is there an employee representative (union) in the establishment? Include the name, address, and telephone number of the union and/or the employee representative(s). _________________________________________ _____________________________________________________________________ For health hazards: Has the employer administered any tests to determine employee exposure levels to the hazardous conditions or substance? Describe these tests. What were the results? Can the employees get the results (as required by the standards)? __________________________________________________ _____________________________________________________________________ What engineering controls are in place in the area(s) in which the exposed employees work? For instance, are there any fans or acoustical insulation in the area which may reduce exposure to the hazard? _____________________________________________________________________ _____________________________________________________________________ What administrative or work practice controls has the employer put into effect? _____________________________________________________________ Do any employees have any symptoms which may have been caused by exposure to hazardous substances? Have any employees ever been treated by a physician for work-related disease or condition? What was it? _____________________________________________________________________ _____________________________________________________________________ Have there been any "near-miss" accidents? __________________________ _____________________________________________________________________ Are respirators worn to protect against health hazards, and if so, what kinds? What exposures are they protecting against? _____________________________________________________________________ If the complaint is related to noise, what, if any, hearing protection is provided to and worn by the employees? ___________________________ _____________________________________________________________________ For safety hazards: Under what adverse or hazardous conditions are employees required to work? This should include conditions contributing to stress and "other" probability factors. ________________________________________________ _____________________________________________________________________ Have any employees been injured as a result of this hazardous condition? Have there been any "near miss" incidents?___________________________ _____________________________________________________________________ APPENDIX C SAMPLE LETTERS Re: Complaint No. Dear : On the Occupational Safety and Health Administration (OSHA) received notice of safety and health hazards at your worksite. We notified you, by telephone, of these alleged hazards on ______. The specific nature of the alleged hazards is as follows: We have not determined whether the hazards, as alleged, exist at your workplace; and we do not intend to conduct an inspection at this time. However, since allegations of violations have been made, we request that you immediately investigate the alleged conditions and make any necessary corrections or modifications. Please advise me in writing, no later that of the results of your investigation. You must provide supporting documentation of your findings, including any applicable measurements or monitoring results, and photographs which you believe would be helpful, as well as a description of any corrective action you have taken or are in the process of taking. This letter is not a citation or a notification of proposed penalty which, according to the OSH Act may be issued only after an inspection of the workplace. It is our goal to assure that hazards are promptly identified and eliminated. Please take immediate corrective action where needed. We encourage employee participation in investigating and responding to any alleged hazard. If we do not receive a response from you by indicating that appropriate action has been taken or that no hazard exists and why, an OSHA inspection will likely be conducted. An inspection may include a review of the following: injury and illness records, hazard communication, personal protective equipment, emergency action or response, bloodborne pathogens, confined space entry, lockout/tagout and related safety and health issues. Please note, however, that OSHA selects for inspection some cases where we have received letters in which employers have indicated satisfactory corrective action. This is to ensure that employers have actually taken the action stated in their letters. The State of ______ offers OSHA consultation services without charge, to assist in resolving all occupational safety and health issues. However, the variety of services available or the scheduling of those services may be limited by the consultation project's requirement to give priority to small businesses in high hazard industries and by its backlog. To discuss or request the services call the following number: You are requested to post a copy of this letter where it will be readily accessible for review by all of your employees and return a copy of the signed Certificate of Posting (Attachment A) to this office. In addition, you are requested to provide a copy of this letter and your response to a representative of any recognized union or safety committee if these are at your facility. Failure to do so may result in an on-site inspection. The complainant has been furnished a copy of this letter and will be provided a copy of your response. Section 11(c) of the OSH Act provides protection for employees against discrimination because of their involvement in protected safety and health activity. If you have any question concerning this matter, please contact __________ at the address in the letterhead. Your personal support and interest in safety and health of your employees is appreciated. Sincerely, Attachment A CERTIFICATE OF POSTING OSHA NOTIFICATION OF ALLEGED HAZARD(S) Complaint Nr: Date of Posting:____________________ Date Copy Given to an Employee Representative:__________ On behalf of the employer, I certify that a copy of the complaint letter received from the Occupational Safety and Health Administration (OSHA) has been posted in a conspicuous place, where all affected employees will have notice, or near such location where the alleged hazardous condition(s) occurred, and such notice has been given to each authorized representative of affected employees, if any. This notice was or will be posted for a minimum of ten (10) working days or until any hazardous conditions found are corrected. _____________________ Signature _____________________ Title ___________________________ Employer/Establishment name Attachment A Dear: In response to your complaint of health and safety hazards at the Occupational Safety and Health Administration (OSHA) has notified requesting that the appropriate action be taken to correct the situation. Enclosed is a copy of that letter for your information. We have not revealed your identity to the employer. When we receive additional information from the employer, a copy of the response will be forwarded to you. Section 11(c) of the OSH Act provides protection for employees against discrimination because of their involvement in protected safety and health related activity. If you believe that you are being treated differently or action is being taken against you because of your safety or health activity, you may file a complaint with OSHA. You should file this complaint as soon as possible, since OSHA normally can only accept complaints filed within 30 days of the alleged discriminatory action. Your continued interest in workplace safety and health is appreciated. Respectfully, Enclosure Re: Dear: We have been advised by that the hazards about which you complained are presently being investigated. Enclosed is a copy of a letter from the employer. The Occupational Safety and Health Administration has requested that the employer submit written notification to us when all corrective action has been completed. A copy of the employer's response will be forwarded to you for your information as soon as we receive it. Respectfully, Enclosures Re: Dear: On ____________ this office sent to you a letter concerning alleged occupational safety and health hazards at your establishment. A copy of the letter is enclosed. We have not received a reply from you concerning these allegations. Please advise this office of your findings and of any corrective action you have taken by ___________. If we do not hear from you, an inspection may be scheduled. OSHA selects for inspection a random sample of cases in which employers have indicated satisfactory corrective action. This policy has been established to ensure that employers have actually taken the action asserted in their letters. If you have any questions concerning this matter, please contact at the above number. Your cooperation in this matter is appreciated. Respectfully, Enclosures Re: Dear: has advised me that the hazards you complained about have been investigated. A copy of the employer's letter is enclosed. With this information, OSHA feels the case can be closed on the grounds that the hazardous conditions have been corrected (or no longer exist). If you do not agree that the hazards you complained about have been satisfactorily abated, please contact us by . If we do not hear from you within that time, we will assume that the hazard has been corrected or eliminated and will take no further action with respect to this case. Your action on behalf of safety and health in the workplace is sincerely appreciated. Respectfully, Enclosures Re: Dear: On the Occupational Safety and Health Administration (OSHA) notified you of alleged safety and/or health hazards at your worksite. Your response to these allegations was received in the Area Office on . Based on our review of the information you provided in your response to these alleged hazards, we have determined that our file on this matter can be closed and no further action on this complaint is anticipated at this time. Please note, however, that the complainant will also be given the opportunity to review the information provided in your response. If the complainant disputes the accuracy of the response, it may be necessary for OSHA to contact you for additional information or documentation of corrective action in order to resolve these issues. In some situations, it may be necessary to conduct an inspection of your workplace. We appreciate your prompt response to these allegations, and your interest in the safety and health of your employees. Please feel free to contact this office if we can be of additional assistance to you. Sincerely, Re: Dear: The purpose of this letter is to acknowledge receipt of your complaint and to inform you that an inspection of this workplace will be scheduled as soon as possible, in accordance with the priorities established by the agency. You will be informed of the results of our inspection when they are available. Section 11(c) of the OSH Act provides protection for employees against discrimination because of their involvement in protected safety or health related activity. If you believe that you are being treated differently or action is being taken against you because of your safety or health activity, you may file a complaint with OSHA. You should file this complaint as soon as possible, since OSHA normally can accept only those complaints filed within 30 days of the alleged discriminatory action. Thank you for your interest in workplace safety and health. Respectfully, Re: Dear: In response to your complaint concerning safety and health hazards at , the Occupational Safety and Health Administration (OSHA) conducted an inspection. That inspection was completed on . The results of our inspection of your complaint items are as follows: Attached for your information is a copy of the OSHA-2, Citation and Notification of Penalty, which was sent to your employer on and should have been posted at the workplace for at least three days after receipt. If you do not agree with our inspection results, you may contact me for a clarification of the matter. You also have the right to an informal review by the OSHA Regional Administrator. This review may be obtained by submitting a written statement of your position to the Regional Administrator. The Regional Administrator will provide the employer with a copy of such statement by certified mail. Your identity will be withheld unless you explicitly request that it be revealed. Section 11(c) of the OSH Act provides protection for employees against discrimination because of their involvement in protected safety and health related activity. If you believe you are being treated differently or action is being taken against you because of your safety or health activity, you may file a complaint with OSHA. You should file this complaint as soon as possible, since OSHA normally can accept only those complaints filed within 30 days of the alleged discriminatory action. Thank you for your concern for a safe and healthy workplace. Respectfully, APPENDIX D IMIS RECORDING A. Instructions for recording complaint data. 1. On the OSHA-7,complete the data items as follows: a. Item #37 - Mark "formal" for signed complaints an "nonformal" for all others. b. Item 39 - Mark box d "nonformal complaint notification to employer." c. Item 40 - "Date letter sent" - write the date the employer was called. d. Item 41 - "Date response due" - write the date which is five working days later. e. Item 42 - Where applicable the following codes will be entered: ID (imminent danger), LP'S (local emphasis program), NP (national emphasis program), DI (disabling injury/illness), SH (significant history), IR (discrimination investigator request), OD (OSHA disputes), ED (employee disputes), CC(companion complaint) or SC (signed complaint). f. Item 46 - "Optional Code" - write N-10-Phone. 2. For complaint inspections on the OSHA 1-B Worksheet, under item 13, REC (Related Event Code), mark the item with a "C" when the violation relates to the complaint. B. Data Entry Options. Enter OSHA-7 into IMIS system and follow menu to process letters to employer and complainant. Complaint allegations from OSHA-7 are drawn into letter to employer by the following commands: Press {shift}{F10} concurrently, then enter /usr/Wp/07/D####### (####### is the complaint number). Alternatively, the notification letter is created to be faxed (or mailed if no fax is available). A macro to create a letter to the contact person at the company can be placed in the office NCR system, thereby enabling letter creation without entering the OSHA-7. 1. From a new word processing machine screen pull up macro by pressing BLUE and F10 keys. The macro is entitled "cip" -- type "cip" and return to bring up the special complaint letter format. 2. Edit the letter as noted by the () for the information specific to the complaint. To move quickly through the letter, search F2 with a (. 3. If a choice is made to save the letter, give it a new name and directory.