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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 2, 1997

Brian J. Murphy
Services Supervisor
Union Camp Corp.
PO Box 459
Seaboard, NC 27876

Dear Mr. Murphy:

Thank you for your letter dated July 28, 1997 requesting an interpretation about a recordkeeping case. Please excuse the delay in our response. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses by page and Q&A number(s) whenever possible.

The first criterion for determining recordability is whether or not the case results from a work accident or an exposure in the work environment (Chart 2, page 32). Preexisting conditions usually do not affect determinations of recordability under the OSH Act. If it seems likely that an event or exposure in the work environment either caused or contributed to the case, the case is work related (B17, page 32). Since the employee's symptoms surfaced on the employer's premises, a work relationship is presumed, particularly since he performed his normal duties for approximately 8 hours before stating that he could not do his job.

The question is whether the symptoms were the result of an identifiable event or exposure in the work environment for there to be a recordable case (B-17, page 32). In this case, the employee was involved in an automobile accident prior to reporting for work and the employee told the shift supervisor that he "felt funny" when he arrived at work at 6:12 PM. However, he was able to perform his normal duties until approximately 2:00 AM when he was unable to pry a conveyor chain. If it seems likely that an event or exposure in the work environment either caused or contributed to the case, the case is work related, even though the exact time or location of the particular event or exposure cannot be identified (B17, page 32). Since we cannot be certain if the back injury resulted solely from the accident or was the result of the pushing motion at work, the case is considered work related.

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 Requirements