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 1, 1992

Ms. ReNae A. Nachman
Dinse, Erdmann & Clapp
Attorneys at Law
P.O. Box 988
Burlington, Vermont 05402-0988

Dear Ms. Nachman:

This is in response to your letter of September 9, to the Occupational Safety and Health Administration (OSHA). Under the Freedom of Information Act (FOIA) you requested a copy of a memorandum dated July 15, 1991, from Region I to OSHA regarding a Sage Products sharps disposal container.

While a reasonable search was made to identify any records at the OSHA National Office that might be responsive to your request, we have not been able to discover the kind of memorandum on or about July 15, 1991, that you are seeking.

The State of Vermont operates its own occupational safety and health program under a State plan approved and monitored by the U.S. Department of Labor pursuant to Section 18 of the Occupational Safety and Health Act. For records related to any inspections of or visits to facilities in Vermont, you should direct any further inquiries to the Vermont Department of Labor and Industry at the address and telephone number shown below:

           Vermont Department of Labor and Industry 
           120 State Street
           Montpelier, Vermont  05620 
           Telephone:  (802) 828-2765

The office listed above will inform you of the total amount of fees, if applicable, and of the appeal procedures available to you under the FOIA.


Roger A. Clark,
Acting Director
Directorate of Compliance Programs