Standard Interpretations - Table of Contents|
| Standard Number:||1904.33; 1904.33(b)(1)|
|This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.|
Section 1904.33 provides in pertinent part that an employer must update the OSHA 300 Logs to include any changes in the description of a recorded injury or illness. It is common for a plant nurse initially to describe a condition as a "strain." When the employee is then seen by outside treating physicians, the physicians typically make a formal diagnosis, such as "tendonitis," "tenosynovitis," "epicondylitis," etc. If an employee is evaluated by a number of different physicians, the same condition may be given a number of different diagnoses. Sometimes the diagnosis will be fairly obscure, such as "subacromial impingement," which most lay people would not understand.Response: Section 1904.33 deals with the retention and updating of the OSHA Part 1904 records after they have been created and summarized. This requires the employer to update the entries on the OSHA 300 Log and to show changes that have occurred to previously recorded cases.
Are employers required to change an initial Column F description of "strain" to the most up-to-date diagnosis? Would the failure to enter such a formal diagnosis in Column F result in the issuance of a citation?
1904.33(b)(1) Do I have to update the OSHA 300 Log during the five-year storage period? Yes, during the storage period, you must update your stored OSHA 300 Logs to include newly discovered recordable injuries or illnesses and to show any changes that have occurred in the classification of previously recorded injuries and illnesses. If the description or outcome of a case changes, you must remove or line out the original entry and enter the new information."OSHA would not consider an employer to be in compliance with Section 1904.33 if the employer fails to adequately describe the injury or illness. For example, OSHA would consider an employer not to be in compliance if an injury was originally entered on the OSHA 300 Log as a sprain, and the employer failed to update the log after receiving new information that the injury was a fracture. In this example, the failure to update the log would materially impair the understandability of the nature of the hazards, injuries and illnesses in the workplace. This analysis is consistent with the inspection and citation procedures provided by OSHA to Compliance Safety and Health Officers (CSHO) in the "Recordkeeping Policies and Procedures Manual," CPL 02-00-135., Chapter 2.
|Standard Interpretations - Table of Contents|
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