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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 23, 1996

Mr. William K. Principe
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Thank you for your letter dated June 11, requesting an interpretation regarding the proper recording of Cumulative Trauma Disorder (CTD) cases on the OSHA Log 200. As outlined in our February 9, 1993 letter to the Ford Motor Company, a new CTD case is established if the worker fails to return for "care" within 30 days and returns with similar complaints. "Care" includes the following:

* visits to medical personnel for unresolved signs and symptoms * visits to medical personnel for first aid/medical treatment * taking medication as directed for unresolved signs or symptoms

The criteria outlined in the November 23, 1994 Ford Motor Company internal recording guidance was somewhat more restrictive than the above criteria concerning the ability to keep individual cases "open" and could result in the recording of some additional cases. We therefore felt this approach was in keeping with the Congressional intent of the OSH Act.

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


Bob Whitmore
Division of Recordkeeping Requirements