No. The Standards Improvement Project Phase IV final rule (SIP IV) published on May 14, 2019, removed the requirement for employers to use social security numbers to identify employees in exposure monitoring, medical surveillance, and other records. However, the preamble clarified that the rule does not require employers to remove social security numbers from existing records. Further, the rule does not prohibit employers from continuing to use social security numbers to identify employees. Employers are simply no longer required to include employee social security
numbers in those records.