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February 25, 1992

Ms Felicia J. Bayer
Bristol-Myers
Squibb Pharmaceutical Research Institute
Post Office Box 5100
Wallingford, Connecticut 06492-7660

Dear Ms. Bayer:

Thank you for your letter of February 10, requesting clarification of the OSHA injury and illness recordkeeping requirements. Your questions are 1) is pencil acceptable in completing the OSHA 200 Log, and 2) can white-out be used for corrections on the 200 Log.

It is acceptable to fill out the OSHA injury and illness records (OSHA 200 and 101) with a pencil, pen, typewriter or any other media you wish to use. You may also use correction fluid or any other technique of entry removal that you desire.

The main issue is not the writing instrument used to maintain the injury and illness records but rather that the records be legible, complete and accurate. Any medium that allows you to easily update the records as new and more exact information is obtained may help one to meet their maintenance obligations.

I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463.

Sincerely,



Stephen A. Newell
Acting Director
Office of Statistics