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OSHA interpretation · 1993-01-26

Recordkeeping requirements as applied to sheltered workshops.

← 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.

January 26, 1993 Mr. Brad Brown Planning & Research Associate II Department of Labor Bureau of Labor Standards Research & Statistics Division State House Station #45 Augusta, Maine 04333-0045 Dear Brad: Thank you for your letter dated January 12, requesting an interpretation concerning OSHA recordkeeping requirements as applied to sheltered workshops. As mentioned in your letter, the Standard Industrial Classification for sheltered workshops is 8331, no matter what specific activity they perform. As found on page 5 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses , SIC 8331 is an exempt industry. Therefore sheltered workshops need not keep OSHA injury and illness records unless contacted by the Bureau of Labor Statistics to participate in their Annual Survey. Care must be taken when assigning SIC code 8331. It must be established that the primary function of the company is to provide job training and vocational rehabilitation, and not the manufacture of a product. I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463. Sincerely, Stephen A. Newell 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.