- 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 http://www.osha.gov.
May 17, 1995
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 April 10, requesting an interpretation regarding the proper recording of occupational sprains and strains. As outlined in section D on page 37 of the Recordkeeping Guidelines for Occupational Injury and Illnesses, the nature of the event or exposure which caused or contributed to the case is the determining factor for distinguishing between injuries and illnesses. Injuries are caused by instantaneous events while illnesses are caused by non-instantaneous events.
Therefore, if a sprain or strain was caused by an instantaneous event, it should be recorded as an injury. If a sprain or strain was caused by a non-instantaneous event or exposure, it should be recorded as an illness (See Q&A D-3, page 38 of the Recordkeeping Guidelines). This holds true for all conditions (e.g. hearing loss, hernias, burns, etc.) except cases involving the back. Back cases should always be classified as injuries. This generalization is made to keep the recordkeeping determinations as simple and equitable as possible (See Q&A D-4, page 38 of the Recordkeeping Guidelines). Cases involving the back are the only conditions for which this generalization is made.
I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.
Division of Recordkeeping Requirements