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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 7, 1995

Mr. James F. Smith
Mountain Technical Center
10100 West Ute Avenue
Post Office Box 625005
Littleton, Colorado 80162-5005

Dear Mr. Smith:

Thank you for your letter dated June 27, requesting an interpretation regarding the proper recording of illness cases on the OSHA Log and Summary of Occupational Injuries and Illnesses. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

For OSHA injury and illness recordkeeping purposes, an occupational illness is defined as an abnormal health condition caused or contributed to by a non-instantaneous event or exposure in the work environment. All occupational illnesses, no matter how transient or short lasted, are recordable.

Subjective symptoms such as the feeling of malaise, headache or nausea are not recordable if there is no apparent association with the work environment. However, subjective complaints which are occupational in origin and attributable to non-instantaneous events or exposures must be recorded on the OSHA Log (see Q&A E-16 on page 42 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).

Please be aware that OSHA is currently in the process of revising its injury and illness recordkeeping requirements. In doing so, we are proposing to revise the recording criteria to capture more serious cases and not those which only involve short lived minor signs or symptoms. We anticipate publishing the proposed revision in the Federal Register this summer. I look forward to receiving any comments you may have regarding this matter at that time.

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