- Standard Number:
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.
June 7, 1999
Mr. Jerry A. Jones
Manager, Risk Management
United States Postal Service
475 L'Enfant Plaza, S.W.
Washington, D.C. 20260
Dear Mr. Jones:
Thank you for your May 6, 1999 letter requesting review of the U.S. Postal Service's computer-generated log of injuries and illnesses for equivalency with the OSHA 200, Log and Summary of Occupational Injuries and Illnesses. To meet the requirements of the injury and illness recordkeeping regulations in 29 CFR Part 1904, an acceptable equivalent form must satisfy the following two conditions:
- It must contain the same detail as the OSHA 200, and
- It must be as readable and comprehensible as the OSHA 200 to a person not familiar with it.
We reviewed your form for its compliance with the above criteria. We determined that your computer-generated form can be considered an acceptable equivalent to the OSHA 200.
Please be aware that our review of the form was for equivalency of format only and not for the correctness of case entries. It did not include review of the U.S. Postal Service's definitions, instructions, or overall data collection system. However, we did note that cases on your form involving days away from work or restricted work activity received checks in both columns 2 and 6 or 9 and 13. Columns 6 and 13 of the log are for cases that do not involve days away from work or restricted work activity. If a case has a check in column 2 or 9, there should not be a check in column 6 or 13.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov . If you have any further questions, please feel free to contact me at 202-693-2100.
Richard Fairfax, Director
Directorate of Compliance Programs