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 http://www.osha.gov.
February 17, 1999
Michele J. Elliott
Post Office Box 3178
Winchester, Virginia 22604
Dear Ms. Elliott:
Thank you for your faxed letter, dated October 22, 1998, requesting a written response to the following question, "Is an instantaneous friction blister recordable if it does not require medical treatment or result in restrictions?" Please excuse the delay in our response. I will answer your question by citing the Recordkeeping Guidelines for Occupational Injuries and Illnesses wherever possible.
Section D on Page 37 of the Recordkeeping Guidelines deals with the distinction between injuries and illnesses for recordkeeping purposes. Whether a case involves an injury or illness is determined by the nature of the original event or exposure which caused the case, not by the resulting condition of the affected employee. Injuries are caused by instantaneous events in the work environment. Cases resulting from anything other than instantaneous events are considered illnesses. Historically, "instantaneous" has been defined as a snap of the fingers.
A friction blister which resulted from an instantaneous event is evaluated as an injury for recordkeeping purposes. If it did not involve medical treatment, loss of consciousness, restriction of work or motion or transfer to another job, then the case is not to be recorded.
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) 693-1702.
Cheryle A. Greenaugh
Director, Directorate of Information Technology