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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 5, 1998

Laurence E. Taylor
Aloha Airlines INC.
P.O. Box 30028
Honolulu, HI 96820

Dear Mr. Taylor:

Thank you for your letter dated March 23, 1998, regarding recordkeeping and access to records. I will respond by restating each question and then answering it.

1) Our master records are compiled and maintained at our main office and faxed to the operating locations upon request. This system of information transfer is also utilized to comply with posting requirements. OSHA 200 logs for previous years are maintained at the main office and available on request at any location with minutes via fax. Am I correct in assuming that our procedures meet the requirements of 1904.7, particularly for making records available "in a reasonable manner and at reasonable times?"

An employer may keep the OSHA forms on data processing equipment, at a central location, or both, if three conditions are met as follows:

  1. The employer can enter the data for the OSHA Forms within 6 working days after receiving information that a recordable injury or illness case has occurred, as required by 1904.2 & 4.
  2. The printed records contain all of the information included on the OSHA Forms, as required by 1904.2 & 4.
  3. The employer can provide immediately, upon request, the printed records to anyone provided access to the records, as required by 1904.7. Given the scenario outlined in your letter, you are able to fax the letters to the establishment immediately upon request and therefore you would be considered in compliance with the requirements of 1904.7.

2. Should the results of an employee's audiometric test be recorded in the OSHA logs as an injury or illness when those results show a standard threshold shift in the employee's hearing?

Under Federal OSHA jurisdiction, employers will be cited for not recording work related average threshold shifts of 25dB or more at 2,000, 3,000 and 4,000 Hz, as measured from the employee's original baseline. If you record Standard Threshold Shift (10dB), you are considered to be in compliance. However, some States with occupational safety and health jurisdiction differ from this enforcement policy. I suggest that you contact the Hawaii OSHA office at (808) 588-9116.

Should you have any additional concerns in this matter, please contact the Division of Recordkeeping Requirements at (202) 219-6463. Thank you for your interest in occupational safety and health.


Ruth McCully
Acting Coordinator, OSHA Information Technology