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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.
May 12, 1994
Mr. Jerry A. Carter
Cerro Copper Products Company
Post Office Box 66800
St. Louis, Missouri 63166-6800
Dear Mr. Carter:
Thank you for your letter dated April 14, requesting clarification of the recordkeeping requirements pertaining to completing the OSHA Supplementary Record of Occupational Injuries and Illnesses (OSHA No. 101). I will restate each of your questions and follow with our response.
Q1. Are the five (5) items listed in the Form OSHA 101 instructions the only items that are REQUIRED by regulation to be filled in?
A1. The five items listed in the instructions of OSHA Form 101 refer to the sections on the front of the form. Each section has multiple questions. All of the items in each section are required to be completed.
Q2. Is it a regulatory requirement that all blocks be filled in on Form OSHA 101?
A2. Yes, all questions on the form must be addressed within 6 work days of learning of a recordable injury or illness.
Q3. If it is not a requirement to fill in all the blanks, which ones may be left empty? Which ones filled in?
A3. All items must be addressed.
Q4. If all of the blanks must be filled in, is it acceptable to enter N/A or UNKNOWN in a block?
A4. If the employer does not have sufficient information to answer the question within the 6 workday requirement, unknown may be entered in the block. However, the employer must investigate the case to obtain the information to complete the form in its entirety.
Q5. What action should be taken if the required information is not available within the six day requirement to complete the form?
A5. The employer should enter unknown in the blocks in question. When the employer does obtain additional information needed to complete the form, the form must be updated with that information.
Q6. If an approved State workers' compensation form is used in lieu of the OSHA Form 101, do the same criteria , rules, and guidelines apply to the State workers' compensation form as the OSHA Form 101 for supplemental recordkeeping purposes?
A6. If an alternative form is being used in lieu of the OSHA Form 101, the form must be completed using the OSHA recordkeeping regulations for each OSHA recordable injury or illness. The OSHA recordkeeping regulations apply only to recording injuries and illness for OSHA recordkeeping purposes. They have no effect on workers' compensation or other insurance systems.
As found on page 18 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, an alternative form may be used if it contains identical information to the OSHA Form 101. Furthermore, if the alternative record does not contain all the information of the OSHA Form 101, items can be supplemented by adding the missing items.
I hope you find this information useful. If you have any questions, please contact my staff at Area Code (202) 219-6463.
Division of Recordkeeping Requirements