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 3, 1991

MEMORANDUM FOR:     ALL REGIONAL ADMINISTRATORS

FROM:               PATRICIA K. CLARK, DIRECTOR 
                   DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT:            Favorable Review Commission Decision, Secretary of
                   Labor v. General Motors Corporation, Electro-Motive 
                   Division, Docket Nos.
                   82-630, 84-731 and 84-816

The Review Commission affirmed former Judge Babrick's decision that General Motors seriously violated the 1910.1020 standard by denying employees access to their medical records.

The attached copy is for your information and reference if further litigation results from this decision.

Attachment