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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 30, 1998

Kenneth W. Gerecke
Assistant Regional Administrator
Occupational Safety and Health Administration
3535 Market Street
Philadelphia, PA 19104

Dear Mr. Gerecke:

Thank you for your letter of June 10, 1998 requesting clarification if detectable levels of chemicals in the blood are recordable under the illness criteria only when associated with health effects. The letter to Mr. Ronnie Powell, dated September 2, 1992, to which you referred, represents OSHA's position on this matter.

Tests performed during a routine or event induced medical examination which result in values outside the range of normality indicate an abnormal condition. This abnormal condition will be considered to be work related for OSHA injury and illness recordkeeping purposes if an event or exposure in the workplace either caused or contributed to the abnormal condition. If the abnormal condition is related to a single instantaneous event, the case must be evaluated using the injury criteria. If it is related to a non-instantaneous exposure(s) or event(s), it must be recorded as an occupational illness.

The case you describe, in which polychlorinated biphenyls (PCBs) were detected in the blood of an employee exposed over time to PCBs, would be recordable as an illness if the level were above that expected in nonoccupational populations. Ninety-five percent (95%) of the general population have levels less than 20 ng/mL (ppb) (Kreiss, K. 1985. "Studies on Populations Exposed to Polychlorinated Biphenyls." Environmental Health Perspective 60:193-199). Therefore any level above 19 ng/mL (ppb) would be abnormal and constitute a recordable illness if work related. The presence of health effects in this situation does not impact on the recordability of this case under OSHA injury and illness recordkeeping regulations. This position is analogous to our longstanding interpretation regarding elevated blood-lead levels.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202) 219-6463.


Ruth McCully
Acting Information Technology Coordinator