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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 1, 1996

David K. McKenas M.D.
Corporate Medical Director
American Airlines
MD 5187
Post Office Box 619616
Dallas/Fort Worth, Texas 75261-9616

Dear Dr. McKenas:

Thank you for your letter dated October 8, requesting an interpretation regarding the OSHA injury and illness recording requirements pertaining to cases of Barotitis Media. Wherever possible I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.

For OSHA injury and illness recordkeeping purposes, an occupational illness is defined as any abnormal condition or disorder which results from a non-instantaneous event or exposure within the work environment (page 37, section D). Furthermore, non-instantaneous has been interpreted to mean any amount of time longer than a snap of the fingers. The change in pressure during the decent of the aircraft occurs over a period of time greater than the "snap of the fingers" and any case resulting from this change in pressure must be evaluated as an illness. All occupational illnesses must be recorded.

Work relationship is established under the OSHA recordkeeping system when an injury or illness results from an event or exposure in the work environment. 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). An employee's physical defect or preexisting physical condition does not affect the determination of recordability (Q&A B-14, page 31).

After review of the facts outlined in your letter, we have determined that a case of barotitis media as you described should be recorded on your OSHA No. 200 with an entry in column 7(f). The condition described occurs while the employee is working and is therefore presumed to be work related. The change in pressure during the decent of the aircraft aggravated the employee's condition to the point where there was temporary or permanent damage to the tympanic membrane.

Whether the environmental condition which leads to an injury or illness is "expected" or "unexpected" is not relevant in the OSHA injury and illness recordkeeping decision making process. Recording only injuries and illnesses that result from unexpected environmental conditions would not produce sufficient information to meet the coverage requirements of the OSH Act nor would it meet the needs of OSHA for comprehensive injury and illness information.

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 Requirement