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.
February 22, 1995
Mr. Mitchell S. Allen, Constangy
Brooks & Smith
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557
Dear Mr. Allen:
Thank you for your letter dated January 23, requesting an interpretation concerning the proper recording of cumulative trauma disorders (CTDs) for OSHA injury and illness recordkeeping purposes. When a specific medical condition (e.g. carpal tunnel syndrome, tenosynovitis, epicondylitis, etc.) is clinically diagnosed and determined to by work related, the case must be recorded on the OSHA Log regardless of whether medical treatment, job restrictions or days away were involved. Such a clinical diagnosis should be considered an objective finding. If, however, the medical condition is categorized in general terms such as a "strain", the employer must evaluate the case for objective findings, medical treatment, job restrictions or days away to determine its recordability.
I hope you find this information helpful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Bob Whitmore Chief Division of Recordkeeping Requirements