Qualifications for interpreting/classifying chest roentenograms and maintenance of interpretation forms.

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 https://www.osha.gov.

November 30, 2005

Dr. Jim Rafferty
Arbor Occupational Medicine
2995 Baseline Road, Suite 310
Boulder, CO 80303

Dear Dr. Rafferty:

Thank you for your July 21, 2005, letter to the Occupational Safety and Health Administration (OSHA). You have a few questions regarding OSHA's general industry asbestos standard, 29 CFR 1910.1001, as applied to medical surveillance of asbestos workers and chest roentgenograms. (Roentgenograms are also known as radiographs or x-ray films.)