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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 4, 1996

Mr. Bob Stevenson
Novacor Chemicals Ltd.
Post Office Box 5006
Red Deer, Alberta Canada T4N 6A1

Dear Mr. Stevenson:

Thank you for your facsimile dated April 23, requesting an interpretation for recording an occupational injury in the OSHA injury and illness records. Whenever possible, I will reference the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing the appropriate page and Q&A numbers.

Injuries and illnesses that result from an event or exposure off the employer's premises are work related if the worker was engaged in work related activities or was present as a condition of his or her employment (page 35, Section 2). These criteria must be applied to the scenario outlined in your facsimile. If the employee was injured while performing duties in the interest of the company, the injury would be considered work related. As described in your letter, the employee was working when the accident occurred and therefore the injury must be considered work related.

Dislocations must be evaluated using the criteria found on page 42 of the Guidelines to determine if the injury is minor or not. Criteria (b) states that an injury is not minor if it impairs bodily function such as the normal use of limbs. Because dislocation of a joint impairs the normal use of a body part, it is considered a non-minor injury, and must be recorded if it is determined to be work related. Minor injuries, on the other hand, are recordable if they meet any of the criteria covered in Section F on pages 42 through 44.

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