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December 7, 1994

Patrick J. Beecher, MD Associate Medical Director Occupational Health and Safety Ford Motor Company Post Office Box 1899 Dearborn, Michigan 48121-1899

Dear Dr. Beecher:

Thank you for your letter dated November 23, requesting our review of your recording protocol for work related cumulative trauma disorder cases. Upon review, we find your criteria for defining a "New CTD Case", a "Recordable CTD Case" and a "Closed CTD Case" consistent with our interpretations. When applying these recording criteria to work related CTD cases, you will be in compliance with our current injury and illness recordkeeping requirements.

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

Sincerely,

Bob Whitmore Chief Division of Recordkeeping Requirements

Definition of a New CTD Case

A new CTD case is established when:

* an employee reports signs and/or symptoms related to a new exposure in the workplace for which there is no open case for the same body part, or

* an employee reports signs and/or symptoms related to a CTD case which has been closed.

Definition of a Recordable CTD Case

A CTD case is recordable if either of the following criteria apply:

* The presence of one or more abnormal physical finding(s), ie., objective sign(s); or

* The presence of subjective symptom(s) coupled with either medical treatment, as defined by OSHA, or lost workday(s), ie., days away from work and/or restricted work activity (including transfer or rotation to another job).

Definition of a Closed CTD Case

A CTD case is closed if either of the following criteria apply:

* 30 calendar days have passed since a medical evaluation established complete resolution of signs and symptoms (regardless of ongoing treatment or lost work days) or

* 30 days have passed since the employee received any medical treatment as defined by OSHA for the CTD case, and the employee has been returned to regular work or placed on a permanent restriction as a result of the CTD.

When a case meets the definition of a "closed case" as stated above and a medical evaluation occurs as a result of a scheduled medical follow-up, and all four of the following conditions are met the visit shall not create a new case for OSHA Recordkeeping purposes.

* no worsening of objective signs and/or symptoms,

* no indication for a new temporary restriction,

* no change to the permanent restriction(s) is made or the permanent restriction(s) is made less restrictive, and

* no change in medical treatment prescribed.