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January 10, 1994

Mr. Wayne Melanson
Safety & Environmental Specialist
OSRAM
Sylvania Inc.
201 Charles Street
Maybrook, New York 12543

Dear Mr. Melanson:

Thank you for your letter dated October 26, 1993, requesting an interpretation regarding the proper recording of second degree burns on the OSHA 200 Log. Your letter was forwarded to my office by the New York OSHA Regional Office. My Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

Any work related second degree burn that is larger than a pinhead or any work related third degree burn (regardless of size) is considered a non-minor injury for recordkeeping purposes. As found on page 42 of the Guidelines, a non-minor injury is one that results in damage to the physical structure of a nonsuperficial nature. All work related non-minor injuries must be recorded. Work related first degree burns and pinhead sized second degree burns are considered minor injuries and not recordable by nature. However, first degree burns and pinhead sized second degree burns, like any other minor injury, are recordable if they involve medical treatment (other than first aid), loss of consciousness, transfer to another job, or restriction of work or motion (see pages 28 and 43 of the Guidelines).

I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.

Sincerely,



Bob Whitmore
Chief
Division of Recordkeeping Requirements