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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 http://www.osha.gov.
September 17, 1991
MEMORANDUM FOR: PAUL J. HANSEN, JR. Area Director; Little Rock, Arkansas THRU: LEO CAREY Director, Office of Field Operations GILBERT J. SAULTER Region VI Administrator Attention: Jeffrey C. Rucker Region VI Recordkeeping Coordinator FROM: STEPHEN A. NEWELL Acting Director, Office of Statistics SUBJECT: Recordkeeping Question From Tyson Foods, Inc.
The most comprehensive guidance for the recording of cumulative trauma disorders (CTDs) on the OSHA 200 Log is found on pages 14 and 15 of the Ergonomics Program Management Guidelines For Meatpacking Plants. The meatpacking guidelines provide specific guidance for determining work relationship, deciding whether or not a CTD exists, proper recording on the Log, and case resolution.
The instructions in the meatpacking guidelines are based on the Recordkeeping Guidelines For Occupational Injuries and Illnesses, 1986. On page 40 of the recordkeeping guidelines questions E-3 and E-4 discuss whether or not a physician's diagnosis is required before a case is recordable. In brief, the answer is that an illness (including a CTD) does not have to be diagnosed by a physician to be recorded. For OSHA recordkeeping purposes, diagnosis of an occupational illness involves the recognition of a work-related abnormal condition or disorder. A work relationship is established if an exposure at work either caused or contributed to the onset of symptoms, or aggravated existing symptoms to the point that they meet the OSHA recording criteria. Many work-related CTDs can be recognized by non-medical personnel, and should be recorded on the Log if they meet the criteria in the meatpacking guidelines.