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.

August 18, 1992

William B. Martin
National Account Manager
Facility Management Systems, Inc.
8145 River Drive
Morton Grove, Illinois 60053

Dear Mr. Martin:

This is in response to your letter of June 9, requesting that the Occupational Safety and Health Administration (OSHA) clarify its position on whether employer use of bar code based, PC computer fire and safety equipment inspection and maintenance records systems is acceptable to OSHA.

OSHA had determined previously that systems such as the one described in your letter are acceptable. As long as the specific OSHA requirements for inspection, maintenance and recordkeeping documentation of fire/safety equipment are met, the Agency allows the employer to determine an appropriate method to comply. Additionally, the employer must be able to readily provide OSHA upon request, hard copies of the computer-stored information for purposes of determining employer compliance with the standards.

If you have any questions, please feel free to contact James C. Dillard, of my staff, at (202) 523-8041.


Patricia K. Clark, Director
Directorate of Compliance Programs