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 6, 1995
Mr. Joseph Pascarella
President
Local 1-S, RWDSU
140 West 31st Street
New York, New York 10001
Dear Mr. Pascarella:
Thank you for your letter dated October 16, requesting clarification of the access provisions to the OSHA No. 200, as specified under Title 29 of the Code of Federal Regulations Part 1904.7.
Access to the entire Log and Summary of Occupational Injuries and Illnesses (OSHA No. 200) is to be provided to employees, former employees, and their representatives in a reasonable manner and at a reasonable time. The entire log includes the employer identification section, columns (A) through (F), including the employees' names, columns (1) through (13), and the totals and certification sections. Furthermore, as stated in Q&A A-4 on page 58 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses, the access provisions are not limited to the portion of the Log containing any entry or entries that specifically relate to a particular employee, former employee or group of employees, regardless of who seeks such access.
These access provisions apply to the current log and summary forms, and those being maintained for the 5-year retention period. Redress for failure to comply with the access provisions of the regulations can be obtained through a complaint to OSHA, who may issue citations for failure to provide access under 29 CFR Part 1904.7.
I am also enclosing a copy of the Final Rule regarding this subject published in the Federal Register in 1978. I hope you find this information helpful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements