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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.
May 3, 1994
MEMORANDUM FOR: REGIONAL ADMINISTRATORS ATTENTION: REGIONAL RECORDKEEPING COORDINATORS THRU: JIMMY ROBERTS Office of Field Programs FROM: BOB WHITMORE Office of Statistics SUBJECT: Employer exemptions to the OSHA injury and illness recordkeeping requirements (Part 1904)
It has been brought to our attention that several motor vehicle dealerships have been cited for not keeping the OSHA injury and illness records (OSHA Log 200 and Supplementary Record 101). As you know, SIC 55 is normally exempted from the recordkeeping requirements by 29 CFR Part 1904.16. We feel it is necessary to refamiliarize the field staff with the list of exempted industries and the small employer exemption as found on the attached page 1 of the Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses. Please pass this information on to the Area Offices within your Regions.