Document a4kGBM1bR0y8KobNQDoGqDyoM

(con co) x-f . Interoffice Communication to Distribution From Tom Grumbles Date September 29, 1983 Subject FIXED-POINT MONITORING DATA RECORDKEEPING Some questions have been raised as to the applicability of OSHA monitoring data recordkeeping requirements to fixed-point data. A literal reading of the definition of monitoring data in the standard would appear to include this type data. However, based on a review of this issue by Legal, data produced from fixed-point monitors does not fall under the OSHA recordkeeping requirements. A letter from Michele Malloy concerning this is attached. It should be noted that there are short-term recordkeeping requirements for VCM fixed-point data under EPA regulations. I would reconmend the following: 1. Some type of data summary, probably monthly, should be kept to document plant conditions. 2. Data from specific days, i.e., when contractors are working in the plant, be kept to document environmental conditions in areas that work was being done. Thomas G. Grumbles Attachment Distribution: Sid Pitts Steve Ashby Darrell Riffe Laurie Mauerman A1 Sather Randy Gantz cc M. Malloy Tom Huffman R. D. Gamblin VEV-275560