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:
Oct 24, 2020 00:09 UTC
Reply-To:
Monona Rossol
In-Reply-To:
Re: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020
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?
