Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1904|
May 15, 1996
To: OSHA Regional Offices OSHA Area Offices State Plan Designees Consultation Program Designees From: John Miles Director Directorate of Compliance Programs Re: The Effect of the 1904 Rulemaking Effort of the De Minimis Citation PolicyThe OSHA Field Inspection Reference Manual (FIRM) provides for De Minimis citations in the event that an employer is complying with a proposed standard. This policy should not be applied to the current OSHA proposal for revising the injury and illness recordkeeping system by revising 29 CFR 1904. Furthermore, written or verbal interpretations of the recordkeeping rule should stress the need for employers to continue to use the current system until a final rule to revise the system becomes effective.
Until it is replaced, the current system must be maintained to provide
nationwide consistency of the records for OSHA, the BLS survey of
occupational injury and illnesses, employers and workers. Allowing employers
to adopt the proposed system in the interim could result in harm to the
Nation's safety and health statistics, and lead to inappropriate comparisons
of individual firms with national averages.
|Standard Interpretations - (Archived) Table of Contents|