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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 31, 1993

Mr. Larry S. Valentine
Director of Loss Prevention
Pet Incorporated
400 South 4th Street
St. Louis, Missouri 63102

Dear Mr. Valentine:

Thank you for your letter dated July 7, requesting interpretations on two OSHA injury and illness recordkeeping issues. Your procedure for maintaining and retaining the OSHA Log, as described in your letter, complies with the recordkeeping regulations. Furthermore, employers are allowed to keep as many sets of records as they feel necessary, as long as the most current set of OSHA records are produced upon a request of access to the records by an authorized person.

Your method of entering "Occupation" and "Department" for floating employees is also within compliance of the recordkeeping regulations. The more precise the information, the more useful the records will be for evaluating the safety and health environment of your establishment.

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