- Standard Number:
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.
June 21, 1993
Mr. Jonathan P. Shermer, Jr.
110 South Commerce
Post Office Box 1916
Russellville, Arkansas 72801
Dear Mr. Shermer:
Thank you for your letter dated May 4, requesting information regarding the classification of carpal tunnel syndrome cases. Your letter was forwarded to my office by Roger Stephens. The Office of Statistics is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide. I am enclosing copies of the Recordkeeping Guidelines for Occupational Injuries and Illnesses and Ergonomics Program Management Guidelines for Meatpacking Plants and I refer to the relevant sections of these publications in this response.
Work relationship is established under the OSHA recordkeeping system when an injury or illness results from an event or exposure in the work environment. The general rule is that all injuries and illnesses which result from events or exposures on the employer's premises are presumed to be work related. Furthermore, if it seems likely that an event or exposure in the work environment either caused or contributed to the case, the case is considered work related. It is sufficient for an exposure to only be a contributing and/or aggravating factor to establish work relationship for OSHA recordkeeping purposes. (Q&A C-7 on page 34, Q&A B-17 on page 32, and Q&A E-6 on page 40 of the Recordkeeping Guidelines)
Page 14 of the Ergonomics Guidelines states "This means that 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. Simply stated, unless the illness was caused solely by a non-work-related event or exposure off-premises, the case is presumed to be work related. Examples of work tasks or working conditions that are likely to elicit a work related CTD are as follows:
* Repetitive and/or prolonged physical activities.
* Forceful exertions, usually with the hands.
* Awkward positions of the upper body, including reaching above the shoulders or behind the back, and angulation of the wrists to perform tasks.
* Localized contact areas between the work or work station and the workers body; i.e. contact with surfaces or edges.
* Excessive vibration from power tools.
* Cold temperatures."
For OSHA recordkeeping purposes, an occupational illness is defined as any abnormal condition or disorder resulting from a non-instantaneous event or exposure in the work environment. Furthermore, non-instantaneous has been interpreted to mean any amount of time longer than a snap of the fingers.
Q&A D-5 on page 38 of the Recordkeeping Guidelines specifically addresses the classification of carpal tunnel syndrome: "Carpal tunnel syndrome is a condition involving compression of the median nerve in the wrist which results in tingling, discomfort, and numbness in the thumb, index, and long fingers. Because work related carpal tunnel syndrome cases almost always result from repetitious movement, they should be classified as occupational illnesses."
Please be aware that OSHA recordkeeping requirements and definitions differ from those established under various State workers' compensation laws. Consequently, OSHA recordkeeping determinations should not affect the employer obligations under State workers' compensation systems (page 45, section G of the Recordkeeping Guidelines). Section 4(b)(4) of the Occupational Safety and Health Act provides that the provisions of the Act will not affect workers' compensation liability.
I hope you find this information useful. If you have any questions, please contact my staff at Area Code (202) 219-6463. The National Institute of Occupational Safety and Health may also be able to provide you with information you need. They can be reached at Area Code (513) 533-8326.
Stephen A. Newell
Office of Statistics