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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 4, 1996

P. R. Larsen
Energy & Chemical
Risk Consultants
800 Camino Del Rex
Las Cruces, New Mexico 88001

Dear Mr. Larsen:

Thank you for your letter dated April 10, requesting an interpretation regarding the coverage of the OSHA injury and illness recordkeeping requirements in relation to the Boy Scouts of America. The correct Standard Industrial Classification of the BSA is SIC 8641 - Civil, Social and Fraternal Associations. This includes the organization in general and the scout camps it operates. The BSA and its scout camps are therefore regularly exempt from the OSHA injury and illness recordkeeping requirements.

Employers who are normally exempted from the recordkeeping requirements are required to comply with OSHA standards, display the OSHA poster, and report to OSHA within 8 hours any work related accident that results in a fatality or the hospitalization of three or more employees. These employers must also maintain an OSHA 200 Log if they are notified in writing by the Bureau of Labor Statistics that they have been selected to participate in the Annual Survey of Occupational Injuries and Illnesses.

Volunteers are generally not considered employees for recordkeeping purposes if they serve of their own free will and do not receive compensation. Compensation in this context may be wages or salaries, or it may consist solely of non-money benefits.

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


Bob Whitmore
Division of Recordkeeping Requirements