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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 02, 2000

Chris Crossman
Safety Engineer
Chevron Products Company
P.O. Box 25117
Salt Lake City, UT 84125

Dear M. Crossman:

Thank you for your letter of October 15, 1999, a follow up letter to your original letter of July 26, 1999, requesting OSHA's interpretation of 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses, as it applies to an injury due to an epileptic seizure at work. Please excuse the delay in our response, but as Ilma Rosskopf, a member of the Recordkeeping Division in OSHA's Office of Statistics, informed you by phone on 12/09/99, your original letter does not appear to have reached us.

I will respond to your original letter by addressing each issue and referring to the appropriate Q&A and page numbers in the Recordkeeping Guidelines (a.k.a. the Blue Book) whenever possible.

Scenario: An employee suffered a seizure due to epilepsy while working at the refinery. The employee was sitting at his desk when the seizure occurred. During the seizure the employee blacked out and fell out of his chair striking his head and opening a laceration on his head, which required sutures. The employee had not previously been diagnosed with epilepsy. You ask how to classify this injury.

Answer: The incident is classified as an injury due to the laceration to the head received upon falling and the medical treatment of sutures required to treat the laceration.

On Page 32, Section C of the Recordkeeping Guidelines, it is stated: "Work relationship is established under the OSHA recordkeeping system when the injury or illness results from an event or exposure in the work environment. The work environment is primarily composed of: (1) The employer's premises, and (2) other locations where employees are engaged in work-related activities or are present as a condition of their employment." The basis for presuming work relationship for OSHA recordkeeping is that the event occurred in the work environment.

As stated on Page 27 of the Recordkeeping Guidelines, "Recording an injury or illness under the OSHA system does not necessarily imply that management was at fault..." And as Q&A C-7 on Page 34 of the Recordkeeping Guidelines states, "There are cases which occur on the employer's premises that do not seem to have anything to do with the work, but must still be recorded to maintain the simplicity of the recording criteria....These are included to keep relatively simple recording boundaries necessary for maintaining a workable system which can be used by the...million[s of] employers and...employees subject to the recordkeeping regulations." OSHA does not penalize employers for properly recording work related injuries and illnesses on the OSHA 200 Log. On the contrary, OSHA views the full and accurate recording of injuries or illnesses as an integral part of an information gathering process which can be used to develop effective safety and health programs.

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