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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 31, 1993

Mr. Mike France
123 Francois Drive
Lafayette, Louisiana 70507

Dear Mr. France:

Thank you for your letter dated May 25, requesting an interpretation on the proper recording of two cases on the OSHA Log of Occupational Injuries and Illnesses (OSHA 200). Please excuse the lengthy delay in our response. Your letter was forwarded to my office by the Dallas Regional Office. My Division of Recordkeeping Requirements is responsible for the maintenance of the OSHA injury and illness recordkeeping system nationwide. Whenever possible, I will refer to the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the relevant page and Q&A numbers.

Any days away or days of restricted work activity associated with the additional damage to the employee's knee caused by the "physical therapist malpractice" must be counted and applied to the original knee injury case. The affected employee would not have suffered these additional days but for the original occupational knee injury (see Q&A F-17, page 45). For the same reasoning, the case involving the employee's smashed thumb would be classified as a recordable fatality. The employee would not have suffered the adverse reaction to the medication but for the occupational injury.

Please be aware that OSHA recordkeeping requirements differ from those established under various State workers' compensation laws. Workers' compensation criteria should not be substituted for OSHA definitions in determining whether or not a case should be recorded under the OSHA system.

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 Director
Office of Statistics