Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1904|
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:
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.
Acting Coordinator, OSHA Information Technology
|Standard Interpretations - (Archived) Table of Contents|