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OSHA interpretation · 1996-06-04

Recordkeeping Requirements in Relation to the Boy Scouts of America.

← 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.

June 4, 1996 P. R. Larsen Energy & Chemical Risk Consultants 800 Camino Del Rex Las Cruces, New Mexico 88001 Dear Mr. Larsen: Thank you for your letter dated April 10, requesting an interpretation regarding the coverage of the OSHA injury and illness recordkeeping requirements in relation to the Boy Scouts of America. The correct Standard Industrial Classification of the BSA is SIC 8641 - Civil, Social and Fraternal Associations. This includes the organization in general and the scout camps it operates. The BSA and its scout camps are therefore regularly exempt from the OSHA injury and illness recordkeeping requirements. Employers who are normally exempted from the recordkeeping requirements are required to comply with OSHA standards, display the OSHA poster, and report to OSHA within 8 hours any work related accident that results in a fatality or the hospitalization of three or more employees. These employers must also maintain an OSHA 200 Log if they are notified in writing by the Bureau of Labor Statistics that they have been selected to participate in the Annual Survey of Occupational Injuries and Illnesses. Volunteers are generally not considered employees for recordkeeping purposes if they serve of their own free will and do not receive compensation. Compensation in this context may be wages or salaries, or it may consist solely of non-money benefits. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

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.