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OSHA interpretation · 1992-02-25

Pencil entries and/or correction fluid on OSHA 200 Log are acceptable.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

February 25, 1992 Ms Felicia J. Bayer Bristol-Myers Squibb Pharmaceutical Research Institute Post Office Box 5100 Wallingford, Connecticut 06492-7660 Dear Ms. Bayer: Thank you for your letter of February 10, requesting clarification of the OSHA injury and illness recordkeeping requirements. Your questions are 1) is pencil acceptable in completing the OSHA 200 Log, and 2) can white-out be used for corrections on the 200 Log. It is acceptable to fill out the OSHA injury and illness records (OSHA 200 and 101) with a pencil, pen, typewriter or any other media you wish to use. You may also use correction fluid or any other technique of entry removal that you desire. The main issue is not the writing instrument used to maintain the injury and illness records but rather that the records be legible, complete and accurate. Any medium that allows you to easily update the records as new and more exact information is obtained may help one to meet their maintenance obligations. I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463. Sincerely, Stephen A. Newell Acting Director Office of Statistics

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.