OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
December 30, 1983
Gerald M. Brown
Buick Motor Division
902 E. Hamilton Avenue
Flint, Michigan 48550
Dear LT. Brown:
This is in response to your letter of December 5, 1983, requesting a clarification of 29 CFR 157(f)(16).
For the clarification requested, 29 CFR 157(f)(16) pertinently states: "Such evidence shall include the date of test, the test pressure used, and the person or agency performing the test." To be complete, your computer printout for the stored pressure water and dry chemical extinguishers lacks, in its listing, the test pressure used and person or agency performing the test. However, if evidence is otherwise maintained for these two non-listed items, then the evidence would be complete as required by 29 CFR 157(f)(16).
For your carbon dioxide extinguishers tested by a contract vendor, the employer shall have the date of test, the test pressure used and the person or agency performing the test for each of the carbon dioxide extinguishers.
Should you have any further questions, please do not hesitate to contact us.
John F. Miles, Jr., Director
Directorate of Field Operations