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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 17, 1996

Peggy J. Townley
Administration Coordinator
Universal Ensco, Inc.
Post Office Box 570248
Houston, Texas 77257-0248

Dear Ms. Townley:

Thank you for your letter dated May 16, requesting an interpretation regarding the removal of a recorded case from your 1993 OSHA Log. Your letter was transferred to my office from the OSHA Office of Information and Consumer Affairs. The OSHA Office of Statistics is responsible for the administration of the injury and illness recordkeeping system nationwide. Whenever possible, I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.

OSHA recordkeeping requirements and definitions differ from those established under various State workers' compensation laws (page 27). Workers' compensation determinations do not impact the recordability of cases under OSHA recordkeeping requirements (Q&A B-1 on page 26 and Q&A G-2 on page 46). Conversely, OSHA recordkeeping determinations should not affect the employer obligations under State workers' compensation systems (page 45, section G ). Some cases may be covered by workers' compensation but are not recordable; other cases may be OSHA recordable but are not covered by workers' compensation. Workers' compensation criteria should not be substituted for OSHA definitions in determining whether or not a case should be recorded under the OSHA system.

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)

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell
OSHA Office of Statistics