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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 26, 1993

Ms. Lyn E. Lang
Safety Systems Administrator
Aluminum Company of America
ALCOA Building
Pittsburgh, Pennsylvania 15219

Dear Ms. Lang:

Thank you for your letter dated September 23, requesting an interpretation for the proper recording procedure for illnesses contracted outside of the United States. Q&A A-12 on page 4 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses best addresses this situation. Records need not be kept for employees when they are outside the geographic scope of coverage prescribed by Section 4(a) of the Act. Neither case described in your letter would be recordable, as long as the illness exposure occurred outside of the United States and it's territories. More specifically, the second scenario may be treated in the same fashion as symptoms that merely surface on the employers premises, but are the result of a non-work related event or exposure off premises (see Q&A C-8 on page 34 of the Guidelines).

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


Bob Whitmore
Division of Recordkeeping Requirements