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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

November 1, 1999

Dale H. Lyons, CSP
Manager of Safety and Health
Ethyl Petroleum Additives, Inc.
501 Monsanto Avenue
Sauget, Illinois 62201

Dear Mr. Lyons:

Thank you for your letter dated June 7, 1999 asking for a recordkeeping interpretation. I will respond by citing the regulations from 29 CFR Part 1904 and the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Recordkeeping Guidelines), by page and Q&A number(s), whenever possible.

Scenario: An individual fainted and fell down steps on the employer's premises, resulting in muscle strains for which medication and physical therapy were prescribed. From interviews and a review of the employee's history, the treating physician concluded the employee fainted and fell due to a non-occupational condition. Is this a recordable case?

Answer: As you indicated in your letter, Q&A B-14 on Page 31 of the Recordkeeping Guidelines states that if an injury or illness occurring in the work environment results solely from a physical defect, it is not occupational and should not be recordable. However, if the work environment or a work event contributes, any resulting injury or illness is occupational and must be recordable.

In the above scenario, the event is a recordable case. Work relationship is established by the fact that the employee was on company premises during normal work hours. While the fainting spell was due to a non-occupational condition, the fall following the fainting spell is the work event which contributed to the resulting muscle strains. The prescribed medications and physical therapy are medical treatment and make the case recordable (Recordkeeping Guidelines, Page 43).

As you are aware, OSHA is currently in the process of revising its injury and illness recordkeeping requirements. We hope to issue the new recordkeeping rules by the end of 1999, although they will not go into effect until January 1, 2001. You can expect to hear about the new regulations later this year.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements at (202) 693-1702.


Cheryle A. Greenaugh
Director, Directorate of Information Technology