Voluntary safety and health audits under the Occupational Safety and Health Act

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.

September 11, 1996

Mr. Frank White
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place, NW
Washington, D.C. 20036

Dear Mr. White:

Thank you for your letter to Secretary Reich concerning voluntary safety and health audits under the Occupational Safety and Health Act (the Act). Secretary Reich has asked me to respond. I appreciate Organization Resource Counselors' (ORC) interest in this issue. ORC's expertise in occupational safety and health issues is well established, and its views merit careful consideration.

Consumer Products that Contain Hazardous Chemicals.

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.

May 28, 1996

[Name Withheld]

Dear [Name Withheld]:

Thank you for your letter of April 19, addressed to the Honorable Robert Reich, Secretary of Labor, concerning application of the Occupational Safety and Health Administration's (OSHA) Hazard Communication Standard (29 CFR 1910.1200). Your letter raised the issue of applying the Hazard Communication Standard to consumer products that contain hazardous chemicals.

Interpretation concerning 1910.120 requirements for air monitoring, a site safety and health plan, training, and medical surveillance

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.

August 19, 1988

Dr. Paul W. Jonmaire
Ecology and Environment, Inc.
Buffalo Corporate Center
368 Pleasantview Drive
Lancaster, New York 14086

Dear Dr. Jonmaire:

Access to employee exposure and medical records.

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.

 

 

Maintenance of and access to employee medical records.

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.

June 16, 1988

Cathy Bellehumeur
Godfrey & Kahn, S.C.
Attorneys at Law
780 North Water Street
Milwaukee, Wisconsin 53202-3590

Dear Ms. Bellehumeur:

This in response to your inquiry concerning OSHA's provisions on retention of employee medical records with other provisions on physician's non-disclosure of medical information unrelated to employees exposure to airborne chemical contaminants. Please accept my apology for the delay in this response.

Recordkeeping criteria for cumulative trauma disorders.

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 https://www.osha.gov.

July 23, 1990

Ms. Deborah E. Berkowitz Director
Office of Occupational Safety and Health
Collective Bargaining Department
United Food & Commercial Workers
International Union, AFL-CIO & CLC
1775 K Street, N.W.
Washington, D.C. 20006-1598

Dear Ms. Berkowitz:

Thank you for your letter of June 28, regarding recordkeeping criteria for cumulative trauma disorders (CTDs) discussed in the Occupational Safety and Health Administration's (OSHA) forthcoming "Ergonomics Program Management Guidelines for Meatpacking Plants."

Employee access to MSDSs required by 1910.1200 vs. 1910.1020.

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.

 

Minimum width of exit routes; redesignation of 1910.1020.

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 https://www.osha.gov.

April 27, 2000

Mr. Gregory W. Faeth
President
Safety Consulting & Training Services
PO Box 1718
Fairfield, IA 52556

Dear Mr. Faeth:

Interpretation of application of 1910.1020 to Federal agencies.

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 19, 1985

Mr. James M. Peirce
President
National Federation of Federal Employees
Suite 200
2020 K Street, N.W.
Washington, D.C. 20006

Dear Mr. Peirce:

This is in response to your letter of October 31 to Acting Assistant Secretary Patrick R. Tyson, concerning access to employee exposure and medical records.

Interpretation on the application of 1910.1020 to material safety data sheets.

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 8, 1985