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January 6, 1993

MEMORANDUM FOR:     GILBERT J. SAULTER
                   Regional Administrator, Region VI

ATTENTION:          JEFF RUCKER
                   Regional Recordkeeping Coordinator

THRU:               LEO CAREY Director Office of Field Operations

FROM:               STEPHEN A. NEWELL Director Office of Statistics

SUBJECT:            Recordkeeping Interpretation - Hoechst Celanese Corporation

Thank you for your memorandum dated November 19, requesting an
interpretation for the proper recording of a case of hearing loss on the OSHA
Log 200.  When an employee works at multiple sites of the same corporation,
an injury or illness should be recorded on the Log of the establishment where
the accident or illness exposure occurred.  Regarding the situation described
in the letter from Mr. Whitmer of the Hoechst Celanese Corporation, because
the consulting audiologist, Dean A. Harris, Ph.D., is able to say that 100%
of the employee's hearing loss occurred at the Pampa plant, the case should
be recorded on the Log of the Pampa Plant (and lined out on the Log in Corpus
Christi).  The case should be entered using the last date the employee was at
that particular location (the last date of exposure).  Also, please notify
Mr. Whitmer that hearing loss should be recorded as a column 7(f) case,
Disorders Associated with Repeated Trauma, not column 7(e).  If you have any
questions, please contact Bob Whitmore of my staff at Area Code (202)
219-6463.








October 29, 1992

Jeffrey C. Rucker 

Safety Specialist 

US DOL/OSHA 

525 Griffin, Room 602

Dallas, TX  75202


Dear Jeff:

I am sending you information on a case which we have recorded under section
7(e) on our OSHA 200 log.  He was recorded on the log due to a hearing loss.
The employee is currently employed as a capitol estimator and works in an
office 100% of the time.  He was previously employed in the maintenance
department of the Hoechst Celanese Plant in Pampa, Texas.

Our consulting audiologist informed us that the threshold shift should be
recorded on the OSHA 200 log.  After discussion with our group level company
safety staff, it was decided that the case should be put on the Corpus
Christi log because Mr. Barbaree was working at this site when the hearing
test reflected a threshold shift from the baseline.

Based on the letter from the consulting audiologist we wish to line out Mr.
Barbaree's incident from our log.  We would really appreciate a letter from
you interpreting how these incidents should be recorded.  In this particular
case should the incident be logged where the employee was exposed to noise or
where the results became noticeable on the hearing test?  Another confusing
issue is when an employee works at one site, but is injured or becomes ill
while working temporarily at another site, (owned by the same company) in
this case which site should log the injury or illness?

Sincerely,








Y. A. Whitmer 

Safety Engineer