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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.
October 17, 1994
Ms. Tami Dickerson Human Resources Director Pacific Suites 333 Madonna Road San Luis Obispo, California 93405
Dear Ms. Dickerson:
Thank you for your letter dated August 23, requesting information regarding the recording of occupational injuries and illnesses on the OSHA 200 Log. Your letter was forwarded to my office by the Bureau of Labor Statistics. The Division of Recordkeeping Requirements in the OSHA Office of Statistics has the responsibility of administering the injury and illness recordkeeping system nationwide. I am enclosing copies of the Recordkeeping Guidelines for Occupational Injuries and Illnesses and A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses. Chapter V of the Recordkeeping Guidelines provides specific guidance for analyzing the recordability of injury and illness cases.
All work related deaths and illnesses must be recorded into the required OSHA records, the OSHA Log and Summary of Occupational Injuries and Illnesses (OSHA No. 200) and the OSHA Supplementary Record (OSHA No. 101), or equivalent forms. Furthermore, all work related injuries requiring medical treatment or involving loss of consciousness, days away from work, restriction of work or motion, or transfer to another job must also be recorded in the records (see pages 42-43 of the Recordkeeping Guidelines). Given this criteria, you are clearly correct in your interpretation that cases need not involve days away from work or days of restricted work activity to be considered recordable cases for OSHA injury and illness recordkeeping purposes.
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.
Bob Whitmore Chief Division of Recordkeeping Requirements