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.
September 12, 1989
|MEMORANDUM FOR:||EXECUTIVE STAFF
|FROM:||ALAN C. McMILLAN
Acting Assistant Secretary
|SUBJECT:||Requests for Enforcement Data from the IMIS System|
It has come to my attention that requests for enforcement data from the Integrated Management Information System (IMIS) are being sent to and processed by more than one office within our Agency. These requests are coming from within as well as outside OSHA. I am concerned that inconsistent and misinterpreted data is being sent in response to these requests because the requests are being directed to the wrong, or sometimes several, offices. There should be only one source of IMIS enforcement data, and that source is the custodian of the data, the Office of Management Data Systems.
Effective immediately, any Office or Directorate needing IMIS enforcement data to respond to a FOIA or with some other external or internal need for such data, shall respond to the requestor and advise him that his request has been sent to the Office of Management Data Systems. No other office shall provide such data to requestors outside their own Office or Directorate. The Office of Field Programs will continue to be available to provide data interpretation, upon request.