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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 24, 1993

Mr. Michael D. Zoll
Manager of Safety
Alcan Aluminum Corporation
100 Erieview
Post Office Box 6977
Cleveland, Ohio 44101-1977

Dear Mr. Zoll:

Thank you for your letter dated March 18, requesting an interpretation regarding the proper recording of cumulative trauma disorders (CTDs) on the OSHA 200 Log. Your letter was forwarded to my office from the Directorate of Compliance Programs. My Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

The most comprehensive guidance for the recording of CTDs on the OSHA 200 Log is found on pages 14 and 15 of the Ergonomics Program Management Guidelines for Meatpacking Plants (enclosed). The ergonomics guidelines state that a CTD exists if there is at least one physical finding OR at least one subjective symptom combined with 1) medical treatment, 2) lost workdays (includes restricted work activity), or 3) transfer/rotation to another job. Examples of physical findings include positive Tinel's, Phalen's, or Finkelstein's tests; or swelling, redness or deformity; or loss of motion. Subjective symptoms include pain, numbness, tingling, aching, stiffness, or burning.

An illness is considered work related if an exposure at work either caused or contributed to the onset of symptoms or aggravated existing symptoms to the point that they meet OSHA recordability criteria. Unless the illness was caused solely by a non-work related event or exposure off premises, the case is presumed to be work related. If the physician is able to say that your employee's stiffness is in no way aggravated by his or her job duties, then the case would not be considered work related, and therefore not recordable.

Even if the case is determined to be work related, based on the facts outlined in your letter, the employee had a subjective symptom, stiffness, but did not receive any medical treatment. If there were no lost workdays or job rotation/transfer involved, the case need not be recorded.

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


Stephen A. Newell
Office of Statistics