Standard Interpretations - Table of Contents
• Standard Number: 1904; 1904.29; 1904.29(b)(6); 1904.29(b)(9); 1904.35(b)(2); 1904.35(b)(2)(iv)

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

September 9, 2005

Mr. Thomas D. O'Connor
National Labor Relations Board
Division of Advice - 10th Floor
1099 14th Street, NW
Washington, DC 20005

Dear Mr. O'Connor:

This is in response to your August 5, 2005 e-mail question to the Department of Labor's Office of the Solicitor concerning the Occupational Safety and Health Administration's (OSHA's) injury and illness recordkeeping requirements at 29 CFR 1904. Your inquiry has been forwarded to this office so that OSHA may provide you with an official interpretation of its regulation.

In your e-mail you ask whether employee representatives have access to OSHA 300 Log information for both union and non-union employees. Specifically, you ask whether an employer may redact names of non-union employees when it turns over the OSHA 300 Log to an employee representative.

OSHA's regulation at 29 CFR 1904.35(b)(2) provides that employees, former employees, their