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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 9, 1993

Ms. Diane Whittier
Senior Engineer
Westinghouse Electric Corporation
Westinghouse Building
Gateway Center
Pittsburgh, Pennsylvania 15222

Dear Ms. Whittier:

Thank you for your letter dated January 6, requesting interpretations on several OSHA injury and illness recordkeeping issues. I will repeat the scenarios outlined in your letter and address each by referencing the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses whenever possible. Please also accept this as a response to your letter sent to Jim Henry, Region III Recordkeeping Coordinator, concerning the same subject.

Scenario 1

On Thursday, 4/23/92, at 11:50 a.m., a procedure writer who is a daily supervised subcontractor, was in his office area. After taking the vitamin niacin, the employee passed out, striking his head against an unknown object as he fell to the floor. The physician diagnosed a reaction to the niacin as the cause of the fainting. The laceration to the forehead was treated with Steri-strips in lieu of sutures. The employee was returned to normal duties that same day.


This case is recordable as an injury without lost workdays. The general rule is that all injuries and illnesses which result from events or exposures occurring to employees on the employer's premises are presumed to be work related. The nature of the activity which the employee is engaged in at the time of the event or exposure, the degree of employer control over the employee's activity, the preventability of the incident, or the concept of fault do not affect the determination of work relationship. (page 34, Q&A C-7)

The event that makes this case recordable is the fall that resulted in the cut requiring the use of Steri-strips. (page 43) Work relationship is established by the fact that the work environment contributed to the resulting injury. (page 31, Q&A B-14)

Scenario 2

On Tuesday, February 11, 1992, a trainer experienced pain and tingling in the right wrist and forearm after working on a computer for eight hours that day with minimal breaks. The employee reported to the medical aid station and was sent to a private physician. The physician diagnosed the condition as a strain to the right forearm. No medication was prescribed. The employee returned to work the next day. The employee is now taking adequate breaks when typing for an extended period of time.


If we assume that the employee's "strain" is related to a non instantaneous event or exposure in the work environment, the case should be evaluated as a cumulative trauma disorder (CTD)(page 38, Q&As D-3, D-5, D-6). The OSHA 200 recording criteria for conditions classified as CTDs can be found on pages 14 and 15 of the enclosed Ergonomics Program Management Guidelines For Meatpacking Plants. As listed in Section 11(a)(2) on page 14, if only subjective symptoms exist, there must be at least one of the following to be a recordable case: 1) medical treatment; 2) lost workdays; or 3) transfer/rotation to another job. If the employee did not exhibit any physical findings and is able to perform all the duties of his/her normal job, the case described in the above scenario should not be recorded.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell
Office of Statistics