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Subject: Fwd: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020
Date: Friday, October 23, 2020 at 3:12:38 PM
Author: DCHAS Membership Chair <membership**At_Symbol_Here**DCHAS.ORG> 		Next by Date:
Subject: Re: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020
Date: Fri, 23 Oct 2020 21:05:32 +0000
Author: "Stuart, Ralph"

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: Fri, 23 Oct 2020 16:12:26 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: A17102E7-D95E-4FC6-89CD-7C97FC93787E**At_Symbol_Here**me.com
In-Reply-To <13D707E4-775E-4524-8748-4DD8FBF54D03**At_Symbol_Here**dchas.org>


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:

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

Tip #200


Visit OSHA's website to see more safety tips 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

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