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.

February 16, 1993

David Lee Sirott
Regional Client Representative
PHS Multi-Phase Testing
83 S. Eagle Road
Havertown, Pennsylvania 19083

Dear Mr. Sirott:

Thank you for your letter of December 3, 1992 addressed to the Occupational Safety and Health Administration (OSHA) regarding the acceptability of x-rays done on 16" x 17" film in lieu of the 14" x 17" size as specified in several OSHA regulations. Please accept our apology for the delay in this response.

You requested to know whether or not OSHA's position statement as indicated in the May 12, 1983 letter to you, is still in effect, since you had been informed by one of your clients that they had a letter to the contrary.

OSHA's position as stated in the
May 12, 1983 letter to you, remains the same. The use of 16" x 17" chest x-rays in lieu of the 14" x 17" size is generally acceptable for purposes of meeting OSHA's standards. Bear in mind that the May 12, 1983 letter also stipulated that there may be specific requirements under 42 CFR 1937.41 for the chest x-rays of underground coal miners that prohibit the use of any other size film besides the 14" x 17" size.

Thank you for the opportunity to clarify this issue for you.


Ruth McCully, Director
[Office of Health Enforcement]

[Corrected 10/22/2004]


December 3, 1992

Mr. Bruce Hillenbrand
Director of Federal & State Operations
200 Constitution Avenue Room N 3700
Washington, D.C. 20210

Dear Mr. Hillenbrand:

In February of 1983 we requested an interpretation of the acceptability of our 16" x 17" chest x-ray in lieu of the 14" x 17" size specified in OSHA regulations. Enclosed is your letter of response.

Recently we heard of a vendor who claimed to have a letter stating that the 16" x 17" chest x-ray was not acceptable. Would you please re-examine our information and restate your current position regarding the acceptability of the 16" x 17" film format.

Thank you for your prompt assistance. If you have any questions or need any additional information please feel free to contact me at 800-833-3005.


Regional Client Representative


May 12, 1983

Mr. Michael Kleinman
Vice President,
Marketing and Sales
Professional Health Services, Inc.
83 S. Eagle Road
Havertown, Pennsylvania 19083

Dear Mr. Kleinman:

This is in response to your letter of February 2, 1983, requesting an interpretation on the acceptability of X-rays done on 16" x 17" film in lieu of the 14" x 17" size as specified in several OSHA regulations. Please accept my apology for the delay in response.

According to the information that you supplied, the expanded format of the 16" x 17" X-rays appears to be identical in magnification and quality to the regular 14" x 17" size. In this regard, we contacted Dr. Edgar L. Dessen, Chairman of the Task Force on Pneumoconioses of the American College of Radiology. He encourages permitting the larger sized chest X-ray films, since workers with a large frame must at times receive multiple X-ray exposures using the standard sized films, whereas the larger films could accommodate them with a single exposure.

In addition, Ms. Mitzie Martin, Chief of Receiving Center Section of the Examination Processing Branch of NIOSH in Morgantown, was called concerning the question of the storage of the larger X-ray film. She indicated that these X-ray films could be accepted for storage under 29 CFR 1910.1020(h)(3), and that the larger size could be accommodated due to the small volume that would be received, if any were sent at all.

The use of 16" x 17" chest X-rays, therefore, appears to be in compliance with all current OSHA regulations that require 14" x 17" film and therefore are acceptable for this purpose.

For your information, NIOSH's Examination Processing Branch does receive a large volume of chest X-ray films of underground coal miners under provisions of the program covering these workers at 42 CFR 37.41. It is our understanding that these regulations call for X-rays to be taken on 14" X 17" film, with no other size acceptable that could meet the specifications for monitoring in the NIOSH program. You may wish to contact Ms. Martin if you have any further questions; her phone number is (304) 291-4301.

We trust that this clarification is useful. If you have any further questions, please do not hesitate to contact us again.


Bruce Hillenbrand, Acting Director,
[Directorate of Cooperative and State Programs]