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.

April 10, 2000

Robert W. Champion, Jr.
Occupational Safety and Health Specialist
Belvidere Assembly Plant
DaimlerChrysler Corporation
3000 W. Chrysler Drive
Belvidere, Illinois 61998

Dear Mr. Champion:

Thank you for your February 4, 2000 letter concerning the use of a electronic signature pad to record signatures for training classes and computer driven training. We apologize for the delay in responding.

You state that new innovations in computer technology have made possible improvements in how paper trail requirements are handled, potentially relieving safety and hygiene professionals of the burdensome tracking and storing of documentation for mandatory training records. You ask if the Occupational Safety and Health Administration (OSHA) would accept electronic signatures in lieu of hard copy signatures for mandatory OSHA required training records.

OSHA training standards generally require the employer and trainers to sign a certification record which includes the identity of the person(s) trained; signatures of the employees are not required. If you mean that every time the person signs, his or her signature will be electronically stored, then OSHA would have no objection to the use of an electronic signature pad to satisfy the certification requirements.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at www.osha.gov. If you have any further questions, please feel free to contact the [Office of General Industry Enforcement at (202) 693-1850].

Sincerely,

Richard E. Fairfax, Director
[Directorate of Enforcement Programs]

[Corrected 10/22/2004]