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September 20, 1996
Mr. Larry M. Kreh
Manager, Ergonomics and Loss Prevention
PPG Industries, Inc.
Post Office Box 2009
Allison Park, Pennsylvania 15101
Dear Mr. Kreh:
Thank you for your letter requesting a reevaluation of recording injuries
and illnesses associated with voluntary flu shot programs on the OSHA Log and
Summary of Occupational Injuries and Illnesses. As you are aware, OSHA is in
the process of revising its occupational injury and illness recordkeeping
requirements. In a Notice of Proposed Rulemaking published in the February
2, 1996 Federal Register, OSHA proposed to discontinue the requirement to
record the very cases from which you are requesting an exception. OSHA
believes it will not lose any valuable information through the
discontinuation of recording these particular cases and sees no need to delay
this policy until publication of a final rule. Therefore, we are revising
our interpretation and do not consider injuries and illnesses which solely
result from the voluntary flu shot programs on the employers premises to be
work related. These cases are therefore no longer recordable.
Sincerely,
Bob Whitmore, Chief
Division of Recordkeeping Requirements
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