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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

March 5, 1997

Mr. William K. Principe
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Thank you for your letter dated February 13, requesting an interpretation regarding the requirement to update the OSHA Log and Summary of Occupational Injuries and Illnesses. Question B-13 on page 16 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses is in contradiction to Section E. on page 23 of the Guidelines in terms of an employer's responsibility to update the summary section of the Log. Because of this discrepancy, we have made the interpretation that employers are not required to update the summary. However, we do encourage them to do so.

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


Bob Whitmore
Division of Recordkeeping Requirements