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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

December 7, 1994

Patrick J. Beecher, MD Associate Medical Director Occupational Health and Safety Ford Motor Company Post Office Box 1899 Dearborn, Michigan 48121-1899

Dear Dr. Beecher:

Thank you for your letter dated November 23, requesting our review of your recording protocol for work related cumulative trauma disorder cases. Upon review, we find your criteria for defining a "New CTD Case", a "Recordable CTD Case" and a "Closed CTD Case" consistent with our interpretations. When applying these recording criteria to work related CTD cases, you will be in compliance with our current injury and illness recordkeeping requirements.

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


Bob Whitmore Chief Division of Recordkeeping Requirements

Definition of a New CTD Case

A new CTD case is established when:

* an employee reports signs and/or symptoms related to a new exposure in the workplace for which there is no open case for the same body part, or

* an employee reports signs and/or symptoms related to a CTD case which has been closed.

Definition of a Recordable CTD Case

A CTD case is recordable if either of the following criteria apply:

* The presence of one or more abnormal physical finding(s), ie., objective sign(s); or

* The presence of subjective symptom(s) coupled with either medical treatment, as defined by OSHA, or lost workday(s), ie., days away from work and/or restricted work activity (including transfer or rotation to another job).

Definition of a Closed CTD Case

A CTD case is closed if either of the following criteria apply:

* 30 calendar days have passed since a medical evaluation established complete resolution of signs and symptoms (regardless of ongoing treatment or lost work days) or

* 30 days have passed since the employee received any medical treatment as defined by OSHA for the CTD case, and the employee has been returned to regular work or placed on a permanent restriction as a result of the CTD.

When a case meets the definition of a "closed case" as stated above and a medical evaluation occurs as a result of a scheduled medical follow-up, and all four of the following conditions are met the visit shall not create a new case for OSHA Recordkeeping purposes.

* no worsening of objective signs and/or symptoms,

* no indication for a new temporary restriction,

* no change to the permanent restriction(s) is made or the permanent restriction(s) is made less restrictive, and

* no change in medical treatment prescribed.