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.

October 22, 1991

Mr. D.E. Miller
President and Chief Operating Officer
The Gates Corporation
900 South Broadway
Post Office Box 5887
Denver, Colorado 80217

Dear Mr. Miller:

Thank you for your letter of August 20 to Secretary of Labor Lynn Martin, regarding the role of self-audits in safety and health programs.

It is indeed encouraging that you have already incorporated safety and health audits into your program. We share your belief in their utility and efficacy as a tool for all levels of management. You raised a concern that the Occupational Safety and Health Administration (OSHA) may use your self-evaluations against the company in an enforcement action. I must tell you that, if a company fails to treat the significant findings of its audit appropriately and fails to correct serious conditions to which its employees are exposed, the company may very will be involved in an enforcement action. We encourage you, therefore, to continue to take the audit process seriously, and to defend against citations simply and directly, by eliminating whatever hazards you may find.

We appreciate your support and your concern for workplace safety and health. If we may be of assistance to you, please let us know.


Gerard F. Scannell
Assistant Secretary

[Corrected 10/22/2004]