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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.
January 6, 1993
MEMORANDUM FOR: GILBERT J. SAULTER Regional Administrator, Region VI ATTENTION: JEFF RUCKER Regional Recordkeeping Coordinator
THRU: LEO CAREY Director Office of Field Operations
FROM: STEPHEN A. NEWELL Director Office of Statistics
SUBJECT: Recordkeeping Interpretation - Hoechst Celanese Corporation
Thank you for your memorandum dated November 19, requesting an interpretation for the proper recording of a case of hearing loss on the OSHA Log 200. When an employee works at multiple sites of the same corporation, an injury or illness should be recorded on the Log of the establishment where the accident or illness exposure occurred. Regarding the situation described in the letter from Mr. Whitmer of the Hoechst Celanese Corporation, because the consulting audiologist, Dean A. Harris, Ph.D., is able to say that 100% of the employee's hearing loss occurred at the Pampa plant, the case should be recorded on the Log of the Pampa Plant (and lined out on the Log in Corpus Christi). The case should be entered using the last date the employee was at that particular location (the last date of exposure). Also, please notify Mr. Whitmer that hearing loss should be recorded as a column 7(f) case, Disorders Associated with Repeated Trauma, not column 7(e). If you have any questions, please contact Bob Whitmore of my staff at Area Code (202) 219-6463.
October 29, 1992
Jeffrey C. Rucker
525 Griffin, Room 602
Dallas, TX 75202
I am sending you information on a case which we have recorded under section 7(e) on our OSHA 200 log. He was recorded on the log due to a hearing loss. The employee is currently employed as a capitol estimator and works in an office 100% of the time. He was previously employed in the maintenance department of the Hoechst Celanese Plant in Pampa, Texas.
Our consulting audiologist informed us that the threshold shift should be recorded on the OSHA 200 log. After discussion with our group level company safety staff, it was decided that the case should be put on the Corpus Christi log because Mr. Barbaree was working at this site when the hearing test reflected a threshold shift from the baseline.
Based on the letter from the consulting audiologist we wish to line out Mr. Barbaree's incident from our log. We would really appreciate a letter from you interpreting how these incidents should be recorded. In this particular case should the incident be logged where the employee was exposed to noise or where the results became noticeable on the hearing test? Another confusing issue is when an employee works at one site, but is injured or becomes ill while working temporarily at another site, (owned by the same company) in this case which site should log the injury or illness?
Y. A. Whitmer