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 http://www.osha.gov.
March 5, 1997
Mr. William K. Principe
Constangy, Brooks & Smith
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.
Division of Recordkeeping Requirements