From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020
Date: Sat, 24 Oct 2020 00:09:24 +0000
Reply-To: Monona Rossol <actsnyc**At_Symbol_Here**CS.COM>
Message-ID: 577309019.2266662.1603498164794**At_Symbol_Here**mail.yahoo.com
In-Reply-To


There are many laws like Hazcom that require documented training.  I have a list somewhere of about 15 such laws. Monona


-----Original Message-----
From: Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Fri, Oct 23, 2020 4:12 pm
Subject: Re: [DCHAS-L] Fwd: OSHA COVID-19 Tip of the Day for October 23, 2020

No, they cannot. As I recall, there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg. The decision had to do with the Process Safety Management standard, which has specific documentation requirements, and OSHA tried to cite Westvaco for not having some docs that they weren't required by reg to have. Annoyingly, I cannot find the reference, though. Might have been OSHRC, rather than a court, but I can't find it there either.

Figure on it this way: if it hasn't been through public review and comment (via the Administrative Procedures Act processes), then they'd be free to require different docs of different companies, which is kind of the definition of "arbitrary and capricious."

Regards, Dan

Sent from my iPad

On Oct 23, 2020, at 15:17, DCHAS Membership Chair <membership**At_Symbol_Here**dchas.org> wrote:

=EF=BB=BF
I found today's Covid tip from OSHA odd. It's a "good idea" to document safety training? OSHA doesn't require this documentation?

- Ralph

Begin forwarded message:

Subject: OSHA COVID-19 Tip of the Day for October 23, 2020
Date: October 23, 2020 at 9:11:04 AM GMT-4

OSHA COVID-19 Tip of the Day for October 23, 2020
OSHA COVID-19 Tip of the Day




To receive future OSHA COVID-19 safety tips of the day, subscribe online.
To opt out of receiving future tips by email, unsubscribe here

This email was sent to ralph**At_Symbol_Here**rstuartcih.org using GovDelivery Communications Cloud on behalf of: United States Department of Labor =B7 200 Constitution Ave NW =B7 Washington, DC 20210 =B7 1-866-4-USA-DOL (1-866-487-2365) GovDelivery logo

Ralph Stuart, CIH, CCHO
Membership Chair
American Chemical Society Division of Chemical Health and Safety

--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas
--- For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

Previous post   |  Top of Page   |   Next post



The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to secretary@dchas.org.
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.