Proper recording of cumulative trauma disorders (CTDs) on the OSHA 200 log.
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 24, 1993
Mr. Michael D. Zoll
Manager of Safety
Alcan Aluminum Corporation
100 Erieview
Post Office Box 6977
Cleveland, Ohio 44101-1977
Dear Mr. Zoll:
Thank you for your letter dated March 18, requesting an interpretation regarding the proper recording of cumulative trauma disorders (CTDs) on the OSHA 200 Log. Your letter was forwarded to my office from the Directorate of Compliance Programs. My Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.