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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 30, 1991

J. J. Schwerha, M.D.
General Manager - Health Services and Medical Director
United States Steel
600 Grant Street
Pittsburgh, Pennsylvania 15219

Dear Dr. Schwerha:

Thank you for your letter of July 10, 1991 requesting clarification of the OSHA injury and illness recordkeeping requirements for occupational hearing loss cases.

Your letter describes a situation where an audiogram is done in December 1990, but the report is not received from the vendor until January 1991. If the case meets the criteria for recording on the OSHA 200 Log, then the case should be entered on the 1990 Log. Our interpretation is that the date of the audiogram is also the date of the initial diagnosis of illness.

I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463.

Sincerely Yours,

Stephen A. Newell
Acting Director
Office of Statistics