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.
Feburary 19, 1997
Ms. Monica Verros, R.N.,C.O.H.N.
Post Office Box 515, Maildrop #39
Dakota City, Nebraska 68731
Dear Ms. Verros:
Thank you for your letter dated January 22, requesting an interpretation regarding the proper recording procedures for back cases. Whenever possible, I will refer to the Recordkeeping Guidelines of Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.
Q1. An employee performs repetitive work duties and complains of back discomfort which requires restricted work activity and/or prescription medication. Should this be recorded as an injury or an illness?
A1. Back cases should always be classified as injuries. This generalization was made to keep the recordkeeping determinations as simple and equitable as possible (See Q&A D-4, page 38 of the Recordkeeping Guidelines). Cases involving the back are the only conditions for which this generalization was made.
Q2. An employee performs repetitive work duties and complains of arms and back discomfort which requires prescription medication and/or restricted work activity. Should this example be recorded as one illness, or should this be recorded as two cases (injury for the back and an illness for the bilateral arms).
A2. Multiple injuries and illnesses resulting from a single event or exposure are recorded as a single case on the OSHA Log. Because there is more involved than just the back in the above situation, the case should be evaluated on all the information available. This case should be characterized as a cumulative trauma disorder involving multiple body parts, and a check placed in column 7(f), "Disorders associated with repeated trauma".
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