Pre-existing condition and/or specific event/exposure grey areas.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 24, 1992

Mr. Bradford L. Brown
Maine Department of Labor
Bureau of Labor Standards
Research and Statistics Division
State House Station # 45
Augusta, Maine 04333-0045

Dear Mr. Brown:

OSHA's no-fault recordkeeping system requires recording work-related injuries and illnesses, regardless of the level of employer control or non-control involved.

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.

Beth Nelson
State of Wyoming
Department of Employment
Cheyenne Business Center
1510 East Pershing Blvd.
Cheyenne, Wyoming 82002

Dear Ms. Nelson:

This is in response to your letter dated August 14, 2002. Thank you for your comments pertaining to the Occupational Safety and Health Administration's (OSHA) Injury and Illness Recording and Reporting Requirements contained in 29 CFR Part 1904.

Why certain retailers are exempt from injury and illness recordkeeping.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 24, 1992

Ms. Rosalie C. Prano
Manager of Human Resources
MIKASA One
Mikasa Drive
Post Office Box 1549
Secaucus, New Jersey 07096-1549

Dear Ms. Prano:

Workers' compensation or insurance claims and recordkeeping requirements.

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 24, 1992

Mr. C. T. Sullinger
Manager of OSHA Records
Brown & Root, Inc.
Post Office Box 3
Houston, Texas 77001

Dear Mr. Sullinger:

Thank you for your letter of February 18, 1991, requesting interpretations for a series of injury and illness recordkeeping questions. I will address these questions by first restating each one and then answering it. Wherever possible, I will reference the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses, 1986, by referencing the page number and question(s) that apply.

Clarification on how the formula is used by OSHA to calculate incident rates

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 23, 2016

Big Sky Industrial
9711 W Euclid Road
Spokane, WA 99224

Dear Ms. Shulund:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses.

Determining work-related injuries for accidents that occur on a public road or highway

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 23, 2016

Mr. Harry Stollmack
Shawcor Inspection Services
4250 Sam Houston Pkwy. E., Ste. 180
Houston, Texas 77032

Dear Mr. Stollmack:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses.

Evaluating the work-relationship of an injury or illness

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.

September 12, 2016

Mr. Jeff McKinney
One Cochrane Dr.
Pennsboro, WV 26415

Dear Mr. McKinney:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. In your letter you request an interpretation from OSHA regarding the work-relatedness of an eye injury experienced by your employee.

Determining whether daily stretches are considered medical treatment or fist-aid.

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.

December 14, 2015

William Principe
Constangy Brooks Smith & Prophete, LLP
230 Peachtree Street, NW
Suite 2400
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Recording of cases in which a health care professional issues a prescription, whether that prescription is filled or not.

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.


Mr. Danny Dean Harris
Loss Control Manager
Maverick Tube Corp.
Post Office Box 248
Armorel, Arkansas 72310

Dear Mr. Harris:

Determining if the employees experienced an injury or illness due to an exposure.

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.

September 14, 2017

Nichole Winnett
Jackson Lewis P. C.
10701 Parkridge Blvd.
Suite 300
Reston, VA 20191

Dear Ms. Winnett:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the requirements contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. Your letter requests interpretation of an incident involving a work-related exposure to 15% hydrofluoric acid.