- 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.
June 20, 1995
Mr. Brad Brown
Planning & Research Associate II
Department of Labor
Bureau of Labor
Standards Research & Statistics Division
State House Station #45
Augusta, Maine 04333-0045
Thank you for your letter dated May 1, requesting interpretations concerning several OSHA injury and illness recordkeeping issues. I will address each issue by first repeating the question and by referring to the appropriate Q&A and page numbers in the Recordkeeping Guidelines for Occupational Injuries and Illnesses.
Q1. Is someone who travels to attend a class or to a worksite which is different than his/her normal worksite in travel status?
A1. Employees in travel status must be: (1) Outside their normal area of operations, or (2) working off premises for more than a normal workday (such as staying overnight). (Q&A C-22, page 37) "Normal area of operations" is interpreted to include the town or city where the employee normally works and directly adjoining municipalities. Any travel between an employee's residence and a point outside of the employee's normal area of operations is not considered a normal commute and is considered work related.
Q2. Hypertension is OSHA recordable. High blood pressure could be considered a symptom. Do you differentiate between levels of hypertension?
A2. For recordkeeping purposes, an occupational illness is any abnormal condition or disorder resulting from a non-instantaneous event or exposure within the work environment. Any such job related abnormality reported to the employer is recordable if it is clearly work related. The difficulty with these cases, as you know, is in differentiating work and non-work causation (Q&As E-2 and E-4 on page 40). If an employee is diagnosed with hypertension and it is determined to be work related, it must be recorded on the OSHA Log. The level of hypertension is not a determining factor for recordability.
Q3. How do you record for someone injured while in route to work while being on call? Is this considered a normal commute or something different? These persons may be called in more than one time.
A3. An employee's normal commute from home to office is not considered to be work related. (Q&A C-19, page 36) Furthermore, an employee's normal commute is considered to be one round trip per day. For employees who are "on call", travel to and from work is not considered the normal commute and any injury occurring during such travel would be considered work related. This also applies to employees responding and traveling to emergency situations.
I am enclosing a copy of our draft proposed recordkeeping revision as you requested. We hope to publish an NPRM in the Federal Register this summer. 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