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Subject: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020

Date: Oct 23, 2020 19:12 UTC

Author: DCHAS Membership Chair <membership**At_Symbol_Here**DCHAS.ORG>

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Subject: Re: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020

Date: Oct 23, 2020 21:05 UTC

Author: Stuart, Ralph <Ralph.Stuart**At_Symbol_Here**KEENE.EDU>

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From: Daniel Kuespert <0000057d3b6cd9b7-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: Oct 23, 2020 20:12 UTC

Reply-To: ACS Division of Chemical Health and Safety

In-Reply-To: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020

Demystify: 

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=BFI 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:

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