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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 11, 1994

David J. McGuan
Safety Engineering Supervisor
Champion International Corporation
River Road
Post Office Box 1200
Bucksport, Maine 04416

Dear Mr. McGuan:

Thank you for your letter dated November 29, 1993, requesting interpretations for several OSHA injury and illness recordkeeping issues. Your letter was forwarded to this office by the Bureau of Labor Statistics on January 13. My Division of Recordkeeping Requirements is responsible for the maintenance of the injury and illness recordkeeping system nationwide.

The concept of restricted work is based on three criteria as follows:

1. The employee was assigned to another job on a temporary basis, or

2. the employee worked at a permanent job less than full time, or

3. the employee worked at his or her permanently assigned job but could not perform all the duties normally connected with it.

Historically, the phrase, "employee's normal job duties" has been interpreted to include any tasks that the employee performs or may be expected to perform throughout the calendar year.

Scenarios 1 through 5 as outlined in Issue Number 1 of your letter meet criteria number 3 above and should all be recorded as cases involving restricted work activity. The employee in question in each of the scenarios was unable to perform at least some of the job duties that he or she would be expected to perform at sometime during the year.

Scenario number 6 does not contain enough information to allow me to make an interpretation. I am unsure how the term "responsibilities" is defined in your case scenario and whether or not it equates with the OSHA definition of "normal job duties". Again the OSHA definition of "employee's normal job duties" has been interpreted to include any tasks that the employee performs or may be expected to perform throughout the calendar year. The correct interpretation of Scenario 6 must be based on this definition.

If something within the work environment worsens a pre-existing condition or symptom it is considered a work related aggravation. If the existing conditions are aggravated to the point that they meet OSHA recordability criteria, the case must be recorded. A single event or motion is not necessary for establishing work relationship. Any factor in the work environment (e.g. repeated motions, weather, stress, etc.) that is likely to have caused, contributed to or aggravated the condition is enough to establish work relationship, even though an exact event or exposure cannot be identified (page 32, Q&A B-17 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).

All three scenarios outlined in Issue Number 2 in your letter meet this criteria and should be evaluated as new work related cases.

The entire OSHA recordkeeping system is currently being revised. A Notice of Proposed Rulemaking (NPRM) concerning the recording of injuries and illnesses is expected to be published in the Federal Register by this summer. This NPRM will propose multiple changes to the recordkeeping system, including changes to the forms, definitions, and instructions. We look forward to receiving any comments or suggestions from safety specialists such as yourself at that time.

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


Bob Whitmore
Division of Recordkeeping Requirements