Several OSHA injury and illness recordkeeping issues.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 18, 1993

Ms. Monica Verros, R.N., C.O.H.N.
Occupational Health Advisor
IBP, Inc.
Dakota City, Nebraska 68731

Dear Ms. Verros:

Thank you for your letter dated April 27, requesting interpretations on a number of OSHA injury and illness recordkeeping issues. I will restate each of your questions and follow with my response. Whenever possible, I will refer to either the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Bluebook) or the Ergonomics Program Management Guidelines for Meatpacking Plants (Greenbook).

Classification of carpal tunnel syndrome cases.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 21, 1993

Mr. Jonathan P. Shermer, Jr.
110 South Commerce
Post Office Box 1916
Russellville, Arkansas 72801

Dear Mr. Shermer:

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

June 21, 1993

Ms. Gail DuFrane
Abbott Laboratories
1400 Sheridan Road North
Chicago, Illinois 60064

Dear Ms. DuFrane:

Several OSHA injury and illness recordkeeping issues.

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.

THE ISSUES RELATED TO OSHA AND WORK AT HOME ARE PRESENTLY UNDER REVIEW. SEE ASSISTANT SECRETARY JEFFRESS' JANUARY 28, 2000 TESTIMONY REGARDING OSHA COVERAGE OF WORKING AT HOME.

June 21, 1993

Mr. Michael Hall
Program Manager
Safety/Emergency Response IBM
2000 Purchase Street
Purchase, New York 10577

Dear Mr. Hall:

Several OSHA injury and illness recordkeeping issues.

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.

THE ISSUES RELATED TO OSHA AND WORK AT HOME ARE PRESENTLY UNDER REVIEW. SEE ASSISTANT SECRETARY JEFFRESS' JANUARY 28, 2000 TESTIMONY REGARDING OSHA COVERAGE OF WORKING AT HOME.

June 21, 1993

Mr. Neil H. Wasser
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Wasser:

Several OSHA injury and illness recordkeeping issues.

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.

THE ISSUES RELATED TO OSHA AND WORK AT HOME ARE PRESENTLY UNDER REVIEW. SEE ASSISTANT SECRETARY JEFFRESS' JANUARY 28, 2000 TESTIMONY REGARDING OSHA COVERAGE OF WORKING AT HOME.

June 21, 1993

Mr. Patrick R. Tyson
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Tyson:

Several OSHA injury and illness recordkeeping issues.

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.

THE ISSUES RELATED TO OSHA AND WORK AT HOME ARE PRESENTLY UNDER REVIEW. SEE ASSISTANT SECRETARY JEFFRESS' JANUARY 28, 2000 TESTIMONY REGARDING OSHA COVERAGE OF WORKING AT HOME.

June 21, 1993

Mr. James A. Werneke
Hoechst Celanese Corporation
Environment, Health
& Safety Department
Post Office Box 428
Bishop, Texas 78343

Dear Mr. Werneke:

Location and maintenance of OSHA injury and illness records for employees working at off-site locations.

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.

July 14, 1993

Mr. Baruch A. Fellner
Gibson, Dunn & Crutcher
1050 Connecticut Avenue, N.W.
Washington, D.C. 20036-5306

Dear Mr. Fellner:

Thank you for your letter dated June 18, requesting an interpretation concerning the location and maintenance of OSHA injury and illness records for employees working at off-site locations. Guidance on location of records can be found in sections B and C on pages 20 through 22 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Effect termination of employment has on the count of lost workdays for recordkeeping purposes.

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 3, 1993

Mr. C. T. Sullinger
Manager of OSHA Recordkeeping
Brown & Root, Inc.
Post Office Box Three
Houston, Texas 77001-0003

Dear Mr. Sullinger:

Thank you for your letter of July 19, requesting a clarification of the effect termination of employment has on the count of lost workdays for OSHA injury and illness recordkeeping purposes.

Recording restricted work activity on the OSHA 200 Log.

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 3, 1993

Mr. E. R. Dhayer
Exxon Company, U.S.A.
Post Office Box 4692
Houston, Texas 77210-4692

Dear Mr. Dhayer:

Thank you for your letter dated July 2, requesting an interpretation regarding recording restricted work activity on the OSHA 200. Your letter was forwarded to my office from the Houston Area Office. My Division of Recordkeeping Requirements is responsible for the administration of the OSHA injury and illness recordkeeping system nationwide.

The concept of restricted work is based on three criteria as follows: