- 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.
October 7, 1996
Savannah River Company
Post Office Box 816
Aiken, South Carolina 29802
Dear Ms. Padgett:
Thank you for your facsimile dated September 18, requesting and interpretation regarding conflicting medical opinions and determination of the recordability of a case. Cases involving restricted work activity where the employee is restricted on the day of the injury or illness only must be recorded as a case without lost workdays (column 6 or 13) regardless of whether the case is recordable for any other reason (see Q&A C-2, page 52 of the Recordkeeping Guidelines). Decisions made for OSHA injury and illness recordkeeping purposes are not based on hindsight, but must be based on what actually occurred. If the plant physician examines an employee the day after the injury or illness and determines that the employee can work at full capacity, the case should not be considered a lost workday case involving days of restricted work activity. 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