September 17, 1991
MEMORANDUM FOR: PAUL J. HANSEN, JR.
Area Director; Little Rock, Arkansas
THRU: LEO CAREY
Director, Office of Field Operations
GILBERT J. SAULTER
Region VI Administrator
Attention: Jeffrey C. Rucker
Region VI Recordkeeping Coordinator
FROM: STEPHEN A. NEWELL
Acting Director, Office of Statistics
SUBJECT: Recordkeeping Question From Tyson Foods, Inc.
The most comprehensive guidance for the recording of cumulative trauma
disorders (CTDs) on the OSHA 200 Log is found on pages 14 and 15 of the
Ergonomics Program Management Guidelines For Meatpacking Plants. The
meatpacking guidelines provide specific guidance for determining work
relationship, deciding whether or not a CTD exists, proper recording on the
Log, and case resolution.
The instructions in the meatpacking guidelines are based on the
Recordkeeping Guidelines For Occupational Injuries and Illnesses,
1986. On page 40 of the recordkeeping guidelines questions E-3 and E-4
discuss whether or not a physician's diagnosis is required before a case is
recordable. In brief, the answer is that an illness (including a CTD) does
not have to be diagnosed by a physician to be recorded. For OSHA
recordkeeping purposes, diagnosis of an occupational illness involves the
recognition of a work-related abnormal condition or disorder. A work
relationship is established if an exposure at work either caused or
contributed to the onset of symptoms, or aggravated existing symptoms to the
point that they meet the OSHA recording criteria. Many work-related CTDs can
be recognized by non-medical personnel, and should be recorded on the Log if
they meet the criteria in the meatpacking guidelines.