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Boy Scouts injury-log exemption under former rules

Summary Under the former SIC-based injury-log system, OSHA said the Boy Scouts and its camps were regularly exempt from keeping logs, subject to other OSHA duties and a survey-selection exception. Uncompensated volunteers generally were not employees for those records. OSHA archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-06-04-4
Date issued
June 4, 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Volunteers
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 4, 1996

P. R. Larsen
Energy & Chemical
Risk Consultants
[Recipient address omitted]
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

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