- 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.
February 12, 1996
Barry L. Bedaw
District Health and Safety Specialist
Groundwater Technology, Inc.
1245 Kings Road
Schenectady, New York 12303
Dear Mr. Bedaw:
This is in response to your letter of September 21, 1995, requesting an interpretation regarding the recordability of a particular illness case on the OSHA No. 200. Please excuse the delay in our response. Your letter was forwarded to my office by the Directorate of Compliance. The Office of Statistics is responsible for maintaining the injury and illness recordkeeping system nationwide. Wherever possible I will refer to the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.
For OSHA injury and illness recordkeeping purposes, an occupational illness is defined as any abnormal condition or disorder which results from a non-instantaneous event or exposure within the work environment (page 37, section D). An example would be the feeling of nausea, shortness of breath, headache, and a rapid pulse rate resulting from exposure to heat.
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 presumption of work relatedness is rebuttable if the worker is on the employer's premises as a member of the general public or if the employee's symptoms are the result of a non-work related event or exposure off premises and merely surface on the employer's premises (see Q&A C-8, on page 34 of the Guidelines).
Deciding if injuries and illnesses are recordable entails making decisions regarding work relationship, recognition and classification of a condition, and determination of the outcome and extent of the case. All of these decisions must be made in good faith by the employer. The decisions must be made in accordance with the requirements of the OSH Act, 29 CFR Part 1904, and the instructions found in Recordkeeping Guidelines for Occupational Injuries and Illnesses and on the back of the recordkeeping forms (page 25, section B(2)). Information from medical, hospital, or supervisor records should be reviewed along with other pertinent information when making decisions regarding all of the aspects in evaluating injury and illness cases.
After review of the facts outlined in your letter, we have determined that the illness case should be recorded on your OSHA No. 200 with an entry in column 7(e). The symptoms experienced by the employee arose while he was working and are therefore presumed to be work related. The physician was unable to determine that the employee's resulting condition was caused entirely by non-work related events or exposures, in other words, that the hot environment that the worker was exposed to played no part in the ill effects he suffered.
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