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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 20, 1996

Mr. Larry M. Kreh
Manager, Ergonomics and Loss Prevention
PPG Industries, Inc.
Post Office Box 2009
Allison Park, Pennsylvania 15101

Dear Mr. Kreh:

Thank you for your letter requesting a reevaluation of recording injuries and illnesses associated with voluntary flu shot programs on the OSHA Log and Summary of Occupational Injuries and Illnesses. As you are aware, OSHA is in the process of revising its occupational injury and illness recordkeeping requirements. In a Notice of Proposed Rulemaking published in the February 2, 1996 Federal Register, OSHA proposed 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, we are revising our interpretation and do not consider injuries and illnesses which solely result from the voluntary flu shot programs on the employers premises to be work related. These cases are therefore no longer recordable.


Bob Whitmore, Chief
Division of Recordkeeping Requirements