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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 11, 1995

Mr. Kurt F. Boestfleisch, RN, BSN
Senior Operations Coordinator
Clinic Administration
Newport News Shipbuilding
4101 Washington Avenue
Newport News, Virginia 23607

Dear Mr. Boestfleisch:

Thank you for your letter dated April 18, requesting interpretations regarding the proper recording of cumulative trauma disorders for OSHA injury and illness recordkeeping purposes. I will address your questions in the order they were presented.

In order for a new cumulative trauma disorder (CTD) case to be recorded, the following two conditions must be met:

* An employee reports signs 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.

A case is considered to be complete once there is complete resolution of the signs and symptoms. If medical personnel declare a case resolved, and signs and symptoms recur, a new case is established and must be evaluated as such. Furthermore, a case is presumed to be complete if a worker does not return for care for a thirty day period following the cessation of medical treatment and the employee's return to full duty. As stated in your letter, a case in which an employee is currently under medical treatment or on restricted work activity is not considered closed.

When determining a new case involving CTDs occurring in work hardening or transition programs, the same criteria presented above must be applied. If an employee is engaged in the program due to an existing CTD, participation in the program should be considered restricted work activity. A case involving the same body part would not be evaluated as a new case while the employee is currently performing restricted work activity. The same would apply to aggravation of cases during training programs.

The count of days of restricted work activity should center on the employee's ability to perform all of his or her normal job duties. Time spent in ramp-in programs due solely to adherence to company policy (and not to the employee's ability to perform all of his or her normal job duties) is not counted as days of restricted work activity. (Q&A B-17, page 50 of the Recordkeeping Guidelines. The focus of decision making is on the employee's ability to work.

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


Bob Whitmore
Division of Recordkeeping Requirements