APR 17 1989

Mr. D.L. Martin
Safety Director Fischbach Corporation
P.O. Box 59387
2525 Walnut Hill Lane
Dallas, Texas 75229

Dear Mr. Martin:

This is in response to your December 9, 1988, letter and to your telephone conversation with James C. Dillard, of my staff, several weeks ago in which you sought the Occupational Safety and Health Administration's (OSHA) ruling as to whether blank OSHA-200 logs must be maintained at each jobsite where no recordable injuries or illnesses have occurred. The following guidelines are presented from the Bureau of Labor Statistics' Recordkeepinq Guidelines for Occupational Injuries and Illnesses: (Copy enclosed)

a. An employer is not required to maintain blank OSHA-200 logs at the jobsite where there are no recordable injuries and illnesses. However, the summary portion of the OSHA-200 log for such jobsites must be completed with zero entries and retained for a five (5) year period. (See page 13, A-6; p.l5, B-6.) The summary portion must be kept at the jobsite if the construction activity lasts one (I) year or more. Otherwise it can be kept at a field office or an established central location.

b. The summary portion of the OSHA-200 logs must be completed and posted for each establishment during the entire month of February. (See page 15, B-3.)

If there are further questions about this matter, please feel free to contact Mr. Dillard again at FTS 523-8041.

Sincerely,

Thomas J. Shepich, Director Directorate of Compliance Programs

Enclosure

GICA:SGD:JDillard/nc/2/23/89/revised4/11/89/File#129 CC: Shepich/Donnelly/Dillard/Abidir/Carey/Washington M/R: Coordinated with Bob Whitmore

U.S. Department of Labor
Occupational Safety and Health Administration
Washington, D.C. 20210

MEMORANDUM FOR:    RAYMOND DONNELLY, DIRECTOR
                   GENERAL INDUSTRY COMPLIANCE

THROUGH:           THOMAS J. SHEPICH, DIRECTOR DIRECTORATE OF COMPLIANCE
                   PROGRAMS

FROM:              LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS

SUBJECT:           Transfer of Request for Interpretation

Attached is a copy of a request for an interpretation of the recordkeeping requirement regarding the keeping of the OSHA 200 Log (Blank) on jobsites.

Please send your response directly to the requester and provide me with copies as well, to the attention of Herbert Washington of my staff. A copy of our response to the requester is also attached.

Attachments

December 9, 1988

Mr. Leo Carey, Director Office of Field Programs U.S. Department of Labor Occupational Safety and Health Administration 200 Constitution Avenue, N.W., Room N3603 Washington, D.C. 20210

Dear Mr. Carey:

This letter is written in an effort to resolve a question on recordkeeping requirements. Background on this question is as follows:

Fischbach Corporation is a holding company of several large companies involved in construction activities. The holding company provides a service to its operating units which includes generating and updating OSHA 200 logs for the various companies' jobs. This is accomplished via electronic data processing on a monthly basis. For a number of years, an OSHA 200 log was provided for every job with blank logs being generated for jobs on which no recordable injuries had occurred. Multiplying by hundreds of jobs throughout the Corporation, this resulted in a large waste of paper, postage, computer/printer time, etc. In 1986 the Dallas OSHA office was contacted about the necessity of providing blank OSHA 200 logs sheets to jobs on which no recordable injuries or illnesses had occurred. The interpretation received at that time was that blank logs were not required. Based on that discussion, a decision was made to discontinue the waste of generating blank OSHA 200 logs and sending to those jobs. Our computer program was modified accordingly to only print OSHA 200 logs and updates when a recordable injury or illness was inputted.

In recent months our companies in some states have been cited for not having current blank log sheets. Further discussion with OSHA Dallas and Washington, DC. have resulted in conflicting interpretations of the requirement for such items. While we wish to be in compliance, we understandably wish to reduce unnecessary paperwork and other associated costs.

Please provide the official interpretation of the question as to whether blank OSHA 200 logs are required at each jobsite.

Sincerely,

D. L. Martin Safety Director

DLM:cl

DEC 23 1988

Mr. D. Martin Safety Director Fischbach Corporation P.O. Box 59387 2525 Walnut Hill Lane Dallas, Texas 75229

Dear Mr. Martin:

This is an interim response to your letter of December 9, requesting an interpretation of the question as to whether blank Occupational Safety and Health Administration (OSHA) injury/illness logs are required at each jobsite.

We have referred a copy of your letter to the Directorate of Compliance Programs for appropriate attention. That office may be contacting you for further information on your interpretation request. If you wish to contact that office, the address and telephone number are:

Mr. Thomas J. Shepich, Director U.S. Department of Labor - OSHA Directorate of Compliance Programs 200 Constitution Ave. Washington, D.C. 20210

If we can be of further service, please contact us.

Sincerely,

Leo Carey, Director Office of Field Programs

Washington/DFPI gz: 12/19/88 cc: Carey/Taylor/Washington/Chron/Donnelly