Interpretation on whether an injury constituted a restriction of work activity.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

April 17, 1989

Mr. Michael S. McCauley
Quarles & Brady
411 East Wisconsin Avenue
Milwaukee, Wisconsin 53202-4497

Dear Mr. McCauley:

OSHA recordkeeping requirements for Consolidated Rail Corporation.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 25, 1983

Mark E. Lichty
Consolidated Rail Corporation
1138 Six Penn Center Plaza
Philadelphia, PA 19103

Re: OSHA Recordkeeping Requirements

Dear Mr. Lichty:

This letter is in response to your request for a determination of whether Conrail's forms and methods comply with OSHA recordkeeping requirements. You have submitted three forms, S-5, S-17, and CT-75C, and Conrail's instructions for compiling the S-5 and the S-17 forms.

Employers should record all back cases as injuries.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 8, 1999

Jerry M. Gillooly
Safety Director
Bohl Crane, Inc.
534 Laskey Road
Toledo Ohio 43612


Dear Mr. Gillooly:

Recordkeeping requirements for employees on interstate or international travel.

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 https://www.osha.gov.

June 24, 1999

Linda Ballas
Linda Ballas & Associates
4413 Copper Creek Lane
Toledo, OH 43615

Dear Ms. Ballas:

Thank you for your letter dated February 16, 1999 requesting clarification concerning employees who work or travel overseas. Please excuse the delay in our response. 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.

OSHA recordkeeping regulations are not subject to preemption under Section 4(b)(1) of the OSH Act.

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 https://www.osha.gov.

"This document was published prior to the publication of OSHA's final rule on Ergonomics Program (29 CFR 1910.900, November 14, 2000), and therefore does not necessarily address or reflect the provisions set forth in the final standard."


March 9, 1999

Stuart Flatow
Director of Occupational Safety and Health
American Trucking Associations
2200 Mill Road
Alexandria, Virginia 22314-4677

Dear Mr. Flatow:

Injury and illness recordkeeping: job rotation or transfer for musculoskeletal disorders.

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 https://www.osha.gov.

January 25, 1999

Frank White
Organization Resources Counselors, Inc.
1910 Sunderland Place NW
Washington DC 20036-1608

Dear Mr. White:

Thank you for your letter dated July 27, requesting a clarification of the OSHA injury and illness recordkeeping requirements as they apply to employer efforts to relieve minor musculoskeletal discomfort through job rotation or transfer.

Recordability of heavy metals in blood/urine.

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 https://www.osha.gov.

August 26, 1998

Mr. Jerry D. Bailey
Assistant Regional Administrator
US DOL/OSHA
525 Griffin Street - Room 602
Dallas, TX 75202

Dear Mr. Bailey:

This is in response to your FAX of July 15, 1998 requesting an injury and illness recordkeeping interpretation of a scenario in which employees tested with the presence of heavy metals, such as the inorganic minerals nickel and cobalt, in their blood, but exhibited no symptoms of illness at the time of testing.

Recordability of blood-PCB levels.

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 https://www.osha.gov.

June 30, 1998

Kenneth W. Gerecke
Assistant Regional Administrator
Occupational Safety and Health Administration
3535 Market Street
Philadelphia, PA 19104

Dear Mr. Gerecke:

Thank you for your letter of June 10, 1998 requesting clarification if detectable levels of chemicals in the blood are recordable under the illness criteria only when associated with health effects. The letter to Mr. Ronnie Powell, dated September 2, 1992, to which you referred, represents OSHA's position on this matter.

Injury/illness recordkeeping: access to records (fax);recording standard threshold shifts.

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 https://www.osha.gov.

May 5, 1998

Laurence E. Taylor
Manager-Safety
Aloha Airlines INC.
P.O. Box 30028
Honolulu, HI 96820

Dear Mr. Taylor:

Thank you for your letter dated March 23, 1998, regarding recordkeeping and access to records. I will respond by restating each question and then answering it.

Numerous injury and illness recordkeeping questions.

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 https://www.osha.gov.

Jan Tucker
c/o BPAC Colombia, Bogota
BPAC Houston
BP Plaza 200
Westlake Blvd
Post Office Box 4587
Houston, Texas 77210

Dear Ms. Tucker: