- Standard Number:
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 http://www.osha.gov.
September 10, 1993
Mr. David E. Jones
Ogletree, Deakins, Nash, Smoak & Stewart
3800 One Atlantic Center
1201 West Peachtree Street, N.W.
Atlanta, Georgia 30309
Dear Mr. Jones:
Thank you for your letter dated August 19, requesting an interpretation concerning the location and maintenance of OSHA injury and illness records. Guidance on the location of records can be found in sections B and C on pages 20 through 22 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses.
It is possible to prepare and maintain the Log at an alternate location if two requirements are met: (1) Sufficient information must be available at the alternate location to complete the Log entry within 6 workdays after the receipt of information that a recordable case has occurred; and (2) a copy of the Log updated to within 45 calendar days must be present at all times in the establishment. Please be aware that the location exception applies only to the Log, and not to the other OSHA records (e.g. Supplementary Record of Occupational Injuries and Illnesses, OSHA 101).
If the establishment is capable of printing the Log immediately upon request, it will be considered to be within compliance of 29 CFR 1904.2. Based upon the description of your client's system, we are unable to evaluate it for compliance. However, as we discussed last week, it would depend on whether the system allowed the establishment to print out the required information - - such as by remote terminal -- or if the system merely allowed the establishment to make a request for the information -- such as by telephone. The former would satisfy the above requirement, the latter would not.
I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.
Bob Whitmore Chief
Division of Recordkeeping Requirements