Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

November 13, 1992

Ms. Cynthia L. Marsh
Executive Director
Hospice of Texarkana
Post Office Box 2341
Texarkana, Arkansas 75504

Dear Ms. Marsh:

Thank you for your letter dated September 23, requesting clarification of an OSHA injury and illness recordkeeping issue which was forwarded to my office from the Bureau of Labor Statistics. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide.

As stated on page 1 of the enclosed Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses, an employer who had no more than ten (10) full or part-time employees at any time during the previous calendar year is normally exempted from keeping OSHA injury and illness records. However, normally exempted employers are required to maintain an OSHA 200 Log if they are notified in writing by the Bureau of Labor Statistics that they have been selected to participate in the Annual Survey of Occupational Injuries and Illnesses. These employers must also comply with OSHA standards, display the OSHA poster, and report to OSHA within 48 hours any work related accident that results in a fatality or the hospitalization of five or more employees.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell
Director Office of Statistics