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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 26, 1998

Mr. Jerry D. Bailey
Assistant Regional Administrator
525 Griffin Street - Room 602
Dallas, TX 75202

Dear Mr. Bailey:

This is in response to your FAX of July 15, 1998 requesting an injury and illness recordkeeping interpretation of a scenario in which employees tested with the presence of heavy metals, such as the inorganic minerals nickel and cobalt, in their blood, but exhibited no symptoms of illness at the time of testing.

The scenario that you present is too vague and lacking in detail for recordability. If there is no link to work, do not record the symptoms. Since the employees cannot determine when the symptoms presented themselves or whether the symptoms were due to occupational exposure, they cannot be considered to be work related and are therefore not recordable.

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 is considered 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 tests show abnormal levels of nickel or cobalt in the employees' blood or urine, the case should be recorded as an occupational illness (See similar case concerning detectable levels of chemicals in the blood in 07/30/98 letter to Kenneth W. Gerecke).

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