- 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 https://www.osha.gov.
May 19, 1994
Mr. David E. Jones
Ogletree, Deakins, Nash, Smoak & Stewart
3800 One Atlantic Center
1201 West Peachtree Street, N.W.
Atlanta, Georgia 30309
Dear Mr. Jones:
Thank you for your letter dated April 22, requesting an interpretation concerning the proper recording of cases involving heat related disorders.
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. All occupational illnesses must be recorded. As defined in NIOSH's Occupational Diseases, A Guide To Their Recognition (1977), the physical disabilities caused by excessive heat exposure, in order of increasing severity, are heat rash, heat cramps, heat exhaustion, and heat stroke. If any one of these conditions is diagnosed/recognized and determined to be work related, it must be recorded. Many of the symptoms (both objective and subjective) listed in your letter are associated with these conditions.
Subjective symptoms are not recordable if there is no apparent association with the work environment. Employers should be aware that many subjective complaints, including feeling of malaise, headache, and nausea are symptomatic of a wide range of occupational illnesses, including heat disorders. (page 42, E-16) If a clear relationship exists between the work environment and the employee's symptoms, the case should be recorded.
Within 6 workdays of receiving information that an injury or illness has occurred, the employer must determine whether the case is recordable. Questionable cases should be entered on the Log and lined out at a later date if they are found not to be recordable. If an employer doubts the validity of an employee's alleged injury or illness and there is no substantive or medical evidence supporting the allegation, the employer need not record the case (page 32, B-18 and B-19).
Please be aware that the injury criteria (i.e. medical treatment, days away, restricted work activity, loss of consciousness, and transfer to another job) should only be used when evaluating injuries and illness cases involving cumulative trauma disorders. All other illness cases should be evaluated using only the illness criteria.
I am enclosing a copy of an OSHA News release concerning heat disorders. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Division of Recordkeeping Requirements