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 https://www.osha.gov.

December 28, 1989

Mr. Richard F. Andree, CSP, PE, Ph.D.
Vice President
Director of Safety and Health
Lovell Safety Management Company, Inc.
161 William Street
New York, New York 10038-2607

Dear Mr. Andree:

This is in response to your letter of November 30, 1989, concerning the required retention of x-ray films under 29 CFR 1910.1020.

Standard 29 CFR 1910.1020 does not require retention of x-rays done for fractures or other reasons unassociated with exposure to toxic substances or harmful physical agents.

I appreciate the opportunity to clarify this matter for you.


G.F. Scannell
Assistant Secretary