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Former OSHA injury-log coverage of retail bakeries

Summary A bakery company asked whether its retail stores had to maintain OSHA injury logs. OSHA said retail bakery stores were covered under the then-current industry list and that the small-employer exemption counted workers across the entire firm, not one store. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-02-12-0
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

Jim Dykes, CSP
Corporate Director of Safety
Interstate Brands Corporation
[Recipient address omitted]
Dear Mr. Dykes:

Thank you for your letter dated November 19, 1995, requesting information regarding the coverage of the OSHA injury and illness recordkeeping requirements. Please excuse the delay in our response. Retail bakery stores (SIC 5461) are covered by the injury and illness recordkeeping regulation. Please note on the attached sheet that SIC 54 - Food Stores is not exempted. For the purpose of the small employer exemption, the employment figure refers to the number of employees in the entire firm (i.e. Interstate Brands Corporation), not the number in an individual establishment.

On February 2, OSHA published in the Federal Register a Notice of Proposed Rulemaking (NPRM) which presents its proposed revision to the injury and illness recordkeeping requirements. Included in the proposal is a modification of the industry and small employer exemptions to the recordkeeping requirements. We invite you to comment on the proposed changes and present your views on the utility of the records in establishments such as your small retail stores.

I hope you find this information useful. If you have any further questions, please do not hesitate to contact us.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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