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Recordkeeping Related Letters of Interpretation


  • 02/28/2014 - Clarification of Multiple Business Establishments and Covered Employees.
  • 02/28/2014 - Clarification of a pre-existing injury or illness and recordable events.
  • 06/26/2013 - Determining Whether the Employer is Required to Record a Work-related Injury Sustained by an Employee which was Treated by a Reduction Procedure Performed on Her Dislocated Ring Finger.
  • 08/13/2012 - The Requirements of Submitting OSHA's Recordkeeping Forms to the United States Department of Labor/OSHA.
  • 06/06/2012 - Clarifying the Recordability Criteria of Several Examples Addressing the Issues of Determining Work-relatedness and Covered Employees.
  • 02/01/2012 - Recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses.
  • 08/10/2011 - Clarification of Multiple Business Establishments and Covered Employees.
  • 05/20/2011 - Clarification on whether an exercise regime is first aid or medical treatment.
  • 04/18/2011 - Clarification on recordability when trigger point injections are used for medical treatment and for diagnostic procedures.
  • 03/22/2011 - Recording an absence as days away when PLHCP recommends the employee return to work.
  • 02/25/2011 - Clarification of the terms most authoritative and pre-existing conditions as used for recordkeeping purposes.
  • 11/15/2010 - Determining work-relatedness for injury that occurred in company parking lot.
  • 09/24/2010 - Clarification on most authoritative when multiple medical opinions are provided.
  • 09/07/2010 - Recording says away and/or restricted work activity when employee is able to work part of a shift.
  • 05/21/2010 - Therapeutic exercise is considered medical treatment for recordkeeping purposes.
  • 05/05/2010 - Clarification on pre-existing conditions and recordable incidents.
  • 04/22/2010 - Clarification on recordkeeping exemption for illness resulting from consuming food in the workplace.
  • 02/16/2010 - Clarification of assigned working hours when recording work-related injuires/illnesses.
  • 01/25/2010 - Clarification of the term abnormal condition as used in the Recordkeeping standard.
  • 11/16/2009 - Whether manual joint manipulation is considered first aid or medical treatment for recordkeeping purposes.
  • 10/06/2009 - Clarification of preexisting injury/illness and recordkeeping.
  • 10/06/2009 - Clarification on prescription medications and recordkeeping requirements.
  • 07/28/2009 - Clarification on administering oxygen as a precautionary measure and as medical treatment.
  • 06/22/2009 - Health impacts from shared office equipment.
  • 06/11/2009 - Clarification on the term work environment as used in the Recordkeeping standard.
  • 05/08/2009 - Clarification on when administering oxygen would result in a recordable injury.
  • 05/04/2009 - Determining if a fatality would be considered work-related.
  • 03/31/2009 - Clarification of the term self-inflicted as used in the Recordkeeping standard.
  • 03/30/2009 -Counting restricted days for a part-time employee.
  • 03/30/2009 -Determining work-relatedness for injuries in the home when telecommuting.
  • 02/24/2009 - Determining recordkeeping for work-relatedness of accident occurring during off-site event.
  • 02/09/2009 - Determining work-relatedness for recordkeeping of injury resulting from horseplay.
  • 01/29/2009 - Permissibility of using electronic signature to satisfy the Annual Summary certification for OSHA Form 300-A.
  • 08/26/2008 - Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness.
  • 07/14/2008 - Whether to record two cases of employee injuries sustained in company parking lot during employees commute to work.
  • 08/29/2007 - Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker hearing loss.
  • 05/15/2007 - Clarification of the term "contemporaneous" as used in recordkeeping FAQ 7-10a.
  • 04/03/2007 - Whether damage to employee dentures is a recordable injury.
  • 04/03/2007 - Recording an injury when employer is provided with different medical opinions.
  • 02/06/2007 - Clarification of several recordkeeping scenarios regarding the use of prescription medication in treating a work-related case.
  • 02/06/2007 - Whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms.
  • 02/06/2007 - Whether to record injuries that occur to a contract employee when traveling from an offshore manned platform complex to other downfield fixed platforms.
  • 11/01/2006 - Updating the OSHA 300 Log to show changes in classification of previously recorded injuries/illnesses.
  • 08/03/2006 - Recording an injury when physician recommends restriction but no restricted work is available.
  • 06/23/2006 - No Restricted Work Available.
  • 05/12/2006 - Determination of work-relatedness on a construction site.
  • 05/12/2006 - Recordkeeping requirements when an employer receives two or more differing medical recommendations for an injury/illness.
  • 04/25/2006 - Restrictions from restricted work activities.
  • 04/24/2006 - Determination of a case as days away or restricted work; case must be recorded in manner reflecting what actually occurs.
  • 12/21/2005 - Determining if an injury is considered a new recordkeeping case based on a recurrence of previously recorded symptoms.
  • 11/30/2005 - Clarification on recording days away from work for follow-up visits to doctor while on restricted-duty job and recovery time to stabilize preexisting condition.
  • 11/15/2005 - Once medical treatment beyond first aid has occurred for injury or illness the case must be recorded.
  • 09/09/2005 - Employer obligation to provide access to entire OSHA 300 Logs, including names of both union and non-union employees.
  • 09/01/2005 - 29 CFR Part 1904 OSHA Recordkeeping Regulation applies only within the jurisdictional boundaries of the United States and certain locations listed in OSHAct Sec. 4(a).
  • 03/10/2005 - Clarification of "assigned working hours" for determining recordability of injuries that occur during breaks in the normal work schedule.
  • 03/10/2005 - All prescription medications, including preventive antibiotics, should be considered medical treatment and are recordable.
  • 11/30/2004 - Determination of the date of an injury or illness for OSHA recordkeeping purposes.
  • 08/26/2004 - Recordability of a fatal traffic accident in a foreign project location.
  • 08/26/2004 - Use of glue to close a wound is medical treatment; prescription antibiotics/antiseptics for preventive treatment of a wound is medical treatment.
  • 08/02/2004 - OSHA 300 Log requirements versus HIPAA privacy requirements.
  • 03/04/2004 - Recording criteria for recordkeeping cases involving occupational hearing loss.
  • 01/15/2004 - Evaluation of seven scenarios for work-relatedness and recordkeeping requirements.
  • 01/13/2004 - Determining work-relatedness when the work event or exposure is only one of the discernable causes; not the sole or predominant cause.
  • 12/18/2003 - Posting requirements for the OSHA 300 Log and OSHA 300-A Summary Form.
  • 11/07/2003 - Employee and employee representative access rights to OSHA 300 Log and OSHA 300-A Summary forms.
  • 07/22/2003 - Clarification of Recordkeeping's work-related exception.
  • 06/23/2003 - Recording criteria for cases involving workers from a temporary help service, employee leasing service, or personnel supply service.
  • 05/08/2003 - Baseline audiogram revision due to persistent STS or improved thresholds; revision must be made for each ear separately.
  • 03/19/2003 - Results of an MRI do not negate the recordability of a physician's recommendation.
  • 11/19/2002 - Clarification on determining if an injury or illness is work-related and the recordability of the administration of oxygen.
  • 08/08/2002 - Use of liquid bandages on wounds is considered first aid.
  • 02/06/2002 - OSHA's no-fault recordkeeping system requires recording work-related injuries and illnesses, regardless of the level of employer control or non-control involved.
  • 10/29/2001 - Recording of cases in which a health care professional issues a prescription, whether that prescription is filled or not.

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