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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

Stephen G. Kastensmidt
Brown & Root
OSHA Recordkeeping Administrator
Room (03) 125
4100 Clinton Drive
Houston, Texas 77020-6299

Dear Mr. Kastensmidt:

Thank you for your letter requesting an exception from recording injuries and illnesses associated with voluntary blood drives on the OSHA Log and Summary of Occupational Injuries and Illnesses. Exceptions to the OSHA injury and illnesses recordkeeping requirements are only granted for the manner in which the records are maintained (e.g. location of records, establishment coverage, etc.).

However, we have reevaluated our current position regarding the recording of injuries and illnesses which occur on the employer's premises when they result solely from the donation of blood during voluntary blood drives. As you are aware, OSHA is in the process of revising its occupational injury and illness recordkeeping requirements. We anticipate proposing to discontinue the requirement to record the very cases from which you are requesting an exception. OSHA believes it will not lose any valuable information through the discontinuation of recording these particular cases and sees no need to delay this policy until publication of a final rule. Therefore, injuries and illnesses which solely result from the donation of blood during voluntary blood drives on the employers premises are not considered work related and are not recordable. By addressing this issue through interpretation, rather than granting a specific exception, we will ensure uniform recording practices and preserve the consistency of cases recorded nationwide.

We look forward to receiving comments from your organization concerning this issue when we publish the Notice of Proposed Rulemaking in the Federal Register. If you have any questions or comments before that time, please contact a member of my staff in the Office of Statistics at area code (202) 219-6463.


Joseph A. Dear
Assistant Secretary