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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 25, 1992

Ms Felicia J. Bayer
Squibb Pharmaceutical Research Institute
Post Office Box 5100
Wallingford, Connecticut 06492-7660

Dear Ms. Bayer:

Thank you for your letter of February 10, requesting clarification of the OSHA injury and illness recordkeeping requirements. Your questions are 1) is pencil acceptable in completing the OSHA 200 Log, and 2) can white-out be used for corrections on the 200 Log.

It is acceptable to fill out the OSHA injury and illness records (OSHA 200 and 101) with a pencil, pen, typewriter or any other media you wish to use. You may also use correction fluid or any other technique of entry removal that you desire.

The main issue is not the writing instrument used to maintain the injury and illness records but rather that the records be legible, complete and accurate. Any medium that allows you to easily update the records as new and more exact information is obtained may help one to meet their maintenance obligations.

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.


Stephen A. Newell
Acting Director
Office of Statistics