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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.

August 23, 1995

MEMORANDUM FOR:     LINDA ANKU
                   REGIONAL ADMINISTRATOR

FROM:               RUTH E. MCCULLY, DIRECTOR 
                   Office of Health Compliance Assistance

SUBJECT:            Storage of Chest X-Rays on Digitized Film

This is in response to your April 3rd memorandum concerning the storing of X-ray films containing chest X-rays, on digitized laser film. Two issues are raised with respect to the acceptability of chest X-rays on digitized laser film in lieu of its "original state" as required under 29 CFR 1910.1020(d)(2). The issues are whether the information on chest X-rays can be transferred onto digitized laser film for storage and whether X-rays can be placed directly on the digitized film rather than traditional X-ray film. We apologize for the delay in this response.

In revising 29 CFR 1910.1020, Access to Employee Exposure and Medical Records, the Occupational Safety and Health Administration (OSHA) gave consideration to the issue of storing X-rays on microfilm. OSHA decided that the storing of X-rays on microfilm was acceptable for all types of X-rays except those for chest X-rays. The X-ray preservation requirement for chest X-rays was maintained because of concern that the diagnostic detail of chest X-rays could be lost when the original X-ray is microfilmed.

Although the agency's consideration of alternate storage methods for chest X-rays was mainly focused on the microfilming process, OSHA was clear in its belief that the maintenance of chest X-rays in it "original state" would reduce the likeliness of loss of the diagnostic detail. Therefore, under the provisions of 29 CFR 1910.1020(d)(2), the storage of chest X-rays on digitized laser film would not be in compliance with maintaining the chest X-rays in its "original state." Any technical points that could be raised about the quality of this film storage process over the microfilming process does not provide a basis for pre-emption of compliance with the standard.

Chest X-rays that are imaged directly onto digitized laser film during the X-ray process can be considered as being in the original state for compliance purposes. The standard does not limit the type of medium for collecting and maintaining chest X-rays in its "original state."

If you have any further questions please contact Lewis Ligon of my staff at (202) 219-8036.