Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

May 25, 1983

Mark E. Lichty
Consolidated Rail Corporation
1138 Six Penn Center Plaza
Philadelphia, PA 19103

Re: OSHA Recordkeeping Requirements

Dear Mr. Lichty:

This letter is in response to your request for a determination of whether Conrail's forms and methods comply with OSHA recordkeeping requirements. You have submitted three forms, S-5, S-17, and CT-75C, and Conrail's instructions for compiling the S-5 and the S-17 forms.

Your request has been reviewed by my staff for compliance with the three basic OSHA recordkeeping forms, OSHA-101,102, and 200 and recordkeeping standards, 29 CFR 1904.2 - 1904.6. Our review has concluded that, with the minor clarification and additions detailed below, your procedures will be in full compliance with the requirements. Conrail's forms, S-5 and S-17, provide information equivalent to the OSHA-200 and the OSHA-102, respectively. The third form, CT-75C (personal injury form), will provide information equivalent to the OSHA-101 if the following information is added: (1) the address of the physician, (2) the hospital address, (3) date of the report, and (4) the location of the employer. Since 29 CFR 1904.2 and 1904.4 expressly permit the required information to be provided in an equivalent form, any Conrail facility maintaining S-5 and the CT- 75C with the above additions will be in compliance with the requirement to maintain the OSHA-101 and the OSHA 200. Although no express provision for an equivalent form for the OSHA-102 is stated in 1904.5, the S-17 is sufficiently similar to constitute compliance with the requirement to maintain the OSHA-102. Accordingly, Conrail facilities maintaining the S-17 will be in compliance with the requirement to maintain the OSHA-102.

In reaching these conclusions, we assume that your forms will be kept in compliance with the other OSHA recordkeeping procedures not expressly set forth in your instructions. Both 1904.2 and 1904.4 require that the forms (S-5 and CT- 75C) be completed within 6 working days after receiving information about a reportable injury. In addition, the S-17 and CT-75C forms are required under 1904.6 to be retained for a 5-year period. Conrail must also be cognizant of the requirements of 1904.5 regarding certifying the annual summary and providing that summary to employees not reporting to a fixed establishment on a regular basis.

A copy of this letter will be sent to relevant Area Directors.


John B. Miles, Jr.
Field Coordination