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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 2, 1992

Ms. Jeanne Veverka
Society for Handicapped Citizens
of Medina County, Inc.
4283 Paradise Road
Seville, Ohio 44273-9728

Dear Ms. Veverka:

Your letter dated July 14, 1992 requesting clarification of OSHA recordkeeping issues was forwarded to my office from the Bureau of Labor Statistics. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide.

As stated on page 28 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses, for OSHA recordkeeping purposes, you are required to record information about every occupational death; every nonfatal occupational illness; and those nonfatal occupational minor injuries which involve one or more of the following: loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment (other than first aid).

As stated on page 26 of the Guidelines, workers' compensation determinations should not impact the recordability of cases under OSHA. Some cases may be covered by workers' compensation but are not recordable; others may be OSHA recordable but are not covered by workers' compensation. Cases should be evaluated solely on the basis of OSHA requirements.

As found on page 19 of the Guidelines, the regulations require that injury and illness records be maintained for each establishment, which is defined as a single physical location where business is conducted or where operations are performed. Therefore, each of your 5 separate homes must maintain a separate OSHA Log.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code 202 523-1463.


Stephen A. Newell
Acting Director
Office of Statistics