- 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 https://www.osha.gov.
June 12, 1995
Anita L. Smith
Henry County Commissioners
660 N. Perry
Post Office Box 546
Napoleon, Ohio 43545-0546
Dear Ms. Smith:
Thank you for your letter dated April 19, requesting an interpretation regarding the proper recording of a case for OSHA injury and illness recordkeeping purposes. Whenever possible, I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses (enclosed) by citing the appropriate page and Q&A numbers.
In order to make a proper determination, additional information regarding work relationship is needed. Work relationship is established under the OSHA recordkeeping system when an injury or illness results from an event or exposure in the work environment. The general rule is that all injuries and illnesses which result from events or exposures on the employer's premises are presumed to be work related. Furthermore, if it seems likely that an event or exposure in the work environment either caused or contributed to the case, the case is considered work related. It is sufficient for an exposure to only be a contributing and/or aggravating factor to establish work relationship for OSHA recordkeeping purposes. (Q&A C-7 on page 34, Q&A B-17 on page 32, and Q&A E-6 on page 40)
The employee's condition as described in your letter leads us to believe it was caused, aggravated or precipitated by repeated motion, vibration or pressure. Such cases are classified as a cumulative trauma disorders (CTDs). The most comprehensive guidance for the recording of CTDs on the OSHA 200 Log is found on pages 14 and 15 of the Ergonomics Program Management Guidelines for Meatpacking Plants (enclosed). The ergonomics guidelines state that a recordable CTD exists if there is at least one physical finding OR at least one subjective symptom combined with 1) medical treatment, 2) lost workdays (includes restricted work activity), or 3) transfer/rotation to another job. Examples of physical findings include positive diagnoses, positive Tinel's, Phalen's, or Finkelstein's tests; or swelling, redness or deformity; or loss of motion. Subjective symptoms include pain, numbness, tingling, aching, stiffness, or burning.
Assuming the case described in your is work related and is a CTD, if the anti-inflammation medication is prescription medication and/or the wrist brace immobilized the wrist, the case should be recorded given that the employee received medical treatment for her subjective symptoms.
OSHA recordkeeping requirements and definitions differ from those established under various State workers' compensation laws. Workers' compensation determinations do not impact the recordability of cases under OSHA recordkeeping requirements (page 26). Conversely, OSHA recordkeeping determinations should not affect the employer obligations under State workers' compensation systems (page 45, section G ). Some cases may be covered by workers' compensation but are not recordable; other cases may be OSHA recordable but are not covered by workers' compensation. To determine whether the case would be considered as a workers' compensation claim, you must contact your State Workers' Compensation Agency.
I hope you find this information useful. If you have any further questions, please contact us at Area Code: (202) 219-6463.
Division of Recordkeeping Requirements