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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 12, 1996

Larry L. Young
Extended Employment
Sheltered Workshops
Department of Elementary and
Secondary Education
Post Office Box 480
Jefferson City, Missouri 65102-0480

Dear Mr. Young:

Thank you for your letter dated November 28, 1995, requesting an interpretation concerning OSHA recordkeeping requirements as applied to sheltered workshops. Please excuse the delay in our response.

The Standard Industrial Classification for sheltered workshops is 8331, no matter what specific activity they perform. As found on page 5 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses (attached), SIC 8331 is an exempt industry. Therefore sheltered workshops need not keep OSHA injury and illness records unless contacted by the Bureau of Labor Statistics to participate in their Annual Survey.

Care must be taken when assigning SIC code 8331. It must be established that the primary function of the company is to provide job training and vocational rehabilitation, and not the manufacture of a product.

There are no industry exemptions for the Hazard Communication requirements. If hazardous chemicals are present in your workplace, you must have a written hazcom program.

I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.


Bob Whitmore
Division of Recordkeeping Requirements