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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.
December 19, 1991
MEMORANDUM FOR: JOHN PHILLIPS Regional Administrator, Region VII (Attention: Gary Steele) THRU: LEO CAREY, DIRECTOR Office of Field Programs FROM: STEPHEN NEWELL, ACTING DIRECTOR Office of Statistics SUBJECT: Recordkeeping Interpretation for U.S. West Communications
Thank you for forwarding Ms. Schuller's letter concerning the recording of illness cases that occurred in their Omaha and Walla Walla facilities.
Because the cases she described did not result from an instantaneous event, these cases should be treated under the illness criteria for recordability on the OSHA 200 Log. As noted on page 37, section D, of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, all work related illnesses must be recorded.
Question E-16 on page 42 of the Guidelines addresses the situation of subjective symptoms and work relationship. Due to the fact that 60 employees reported the same symptoms over a two day period, there is little doubt that a work relationship exists. The fact that it may have been a panic attack is of little relevance. This would still be a work related condition.
Since the work relationship and illness criteria are both met in situations 1 through 4 in Omaha and 1 through 3 in Walla Walla, these cases should be recorded on the OSHA 200 Log.
Situation 5 in Omaha and 4 in Walla Walla do not meet the illness criteria for recordability. Exposures in and of themselves, without any resulting consequences, are not recordable on the OSHA 200 Log.
If you have any questions, please contact my staff at (202) 523- 1463.