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Former injury-log exemption for sheltered workshops

Summary A sheltered workshop asked whether it had to keep OSHA injury logs. OSHA said workshops whose primary function was job training and rehabilitation fell under an exempt industry category in the then-current system, unless selected for a federal survey. It said hazard communication duties still applied when hazardous chemicals were present; OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-02-12
Date issued
February 12, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Coverage Hazard Communication
Source
View the official document

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 12, 1996

Larry L. Young
Extended Employment
Sheltered Workshops
Department of Elementary and
Secondary Education
[Recipient address omitted]
Dear Mr. Young:

Thank you for your letter dated November 28, 1995, requesting an interpretation concerning OSHA recordkeeping requirements as applied to sheltered workshops. Please excuse the delay in our response.

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 (attached), 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.

There are no industry exemptions for the Hazard Communication requirements. If hazardous chemicals are present in your workplace, you must have a written hazcom program.

I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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