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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 15, 1995

Glenn Gill
Marketing Coordinator
Ciser Systems Corp.
3-1079 Wellington Avenue
Winnipeg MB Canada R3E 3E8

Dear Mr. Gill:

Thank you for your letter requesting several interpretations regarding OSHA injury and illness recordkeeping requirements. Your letter was forwarded to my office by the Bureau of Labor Statistics. The Division of Recordkeeping Requirements is responsible for maintaining the injury and illness recordkeeping system nationwide. I will address your questions in the order they were presented and wherever possible, refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses (enclosed) by stating the appropriate page and Q&A numbers.

1. It is acceptable to use any technique of entry correction that is desired (e.g. line out, erase, white out, or computer deletion of the original entry and reentry of a case if necessary). The main issue is not the method of correction used, but rather that the records are complete, accurate, and legible.

2. The count of lost workdays (i.e. days away from work and/or days of restricted work activity) include any day on which the employee was unable to work or was restricted except (1) the initial day of injury or onset of illness, and (2) any day on which the employee would not have worked even though able to work (i.e. holidays, weekends, etc.). Thus as noted in your example, your understanding that Tuesday should be counted as a day away from work is correct. (Q&A B-2, page 48)

3. Recordable injuries and illnesses must be entered on the log no later than 6 workdays after the employer learns that a case has occurred. If the case entails lost workdays beyond the 6 day period, the employer should make a good faith estimate of the number of lost workdays the case will require. The same holds true for generating year end totals. When the employee(s) returns to work, the estimate should be replaced with the actual number of workdays lost. (Q&A B-5 & B-6, page 48). There is no set formula for estimating day counts. Whenever possible, please rely on existing medical information and opinion to estimate the day counts (section B.2, page 25).

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