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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 23, 1990

Ms. Deborah E. Berkowitz Director
Office of Occupational Safety and Health
Collective Bargaining Department
United Food & Commercial Workers
International Union, AFL-CIO & CLC
1775 K Street, N.W.
Washington, D.C. 20006-1598

Dear Ms. Berkowitz:

Thank you for your letter of June 28, regarding recordkeeping criteria for cumulative trauma disorders (CTDs) discussed in the Occupational Safety and Health Administration's (OSHA) forthcoming "Ergonomics Program Management Guidelines for Meatpacking Plants."

The criteria outlined in the guidelines for recording CTDs on the OSHA-200 log were carefully developed in discussions between OSHA and the Bureau of Labor Statistics (BLS). They represent an interpretation of OSHA-BLS 1986 "Recordkeeping Guidelines for Occupational Injuries and Illnesses." They are intended to provide employers with clear guidance on when to record a diagnosed or recognized CTD on the OSHA-200 log, to promote the accurate identification of these occupational illnesses.

It was never OSHA's intent that the second visit of an employee to the nurse or health care provider with complaints of subjective symptom(s), e.g., pain, should be recognized as an occupational illness. Rather, in order to provide guidance on when a CTD should be recognized or diagnosed, OSHA and BLS determined that when an employee experiences work-related subjective symptoms only, an illness should be recorded if there is also resulting action: medical treatment (including self-administered treatment when made available to employees by their employer), lost workdays (includes restricted work activity), or transfer/rotation to another job.

Please note that the case must be recorded whenever an employee exhibits any positive physical findings.

These criteria should be considered in light of OSHA's recommendations for the evaluation, treatment, and followup of CTDs in the section of the guidelines on medical management. This section specifically recommends followup of employees who present CTD symptoms, and advises that such employees be referred to a physician if the condition has not resolved within approximately eight days.

While the provision of aspirin (or other nonprescription drugs) is not considered medical treatment in the OSHA-BLS recordkeeping system, this is only one example of the types of conservative treatment recommended when an employee demonstrates subjective symptoms with no positive physical signs present. More importantly, the medical treatment/first aid criteria contained in the BLS injury and illness guidelines provide a consistent definition for use throughout the recordkeeping system.

We share your concerns regarding both the provision of appropriate medical treatment for CTD cases and the necessity of accurate recordkeeping. We believe this underscores the importance of the medical management section of the guidelines--as well as the need for CTD recordability criteria that are clear and consistent--for employers in the meatpacking industry. The questions you raised have been thoroughly reviewed by my staff and by BLS, and we have determined that the guidance given in the current draft of the guidelines is appropriate, reasonable, and in accordance with established interpretations of recordkeeping regulations.

If we may be of further assistance, please feel free to contact us again.


Alan C. McMillan
Deputy Assistant Secretary