When orthopedic devices constitute medical treatment 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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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. Larry M. Kreh Manager,
Ergonomics and Loss Prevention
PPG Industries, Inc.
Post Office Box 2009
Allison Park, Pennsylvania 15101

Dear Mr. Kreh:

Thank you for your facsimile dated July 19, requesting interpretations as to when orthopedic devices constitute medical treatment for OSHA injury and illness recordkeeping purposes. I will repeat each of your questions and follow with my response.

Determination of the proper date of injury or illness for OSHA 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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 18, 1993

Mr. W. William Ament
Organization Resources Counselors, Inc.
1910 Sunderland Place, N.W.
Washington, D.C. 20036

Dear Mr. Ament:

Recordability of cases involving the use of a hand held massager.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

Ms. Susan A. Tate, R.N.
The William Carter Company
2810 North Expressway
Harlingen, Texas 78552

Dear Ms. Tate:

Work relationship of an injury occurring on the company premises.

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 18, 1993

Mr. Stephen G. Kastensmidt
OSHA Recordkeeping Group
Brown & Root, Inc.
Post Office Box Three
Houston, Texas 77001-0003

Dear Mr. Kastensmidt:

Procedure for maintaining and retaining the OSHA 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 31, 1993

Mr. Larry S. Valentine
Director of Loss Prevention
Pet Incorporated
400 South 4th Street
St. Louis, Missouri 63102

Dear Mr. Valentine:

Proper recording on the OSHA Log of Occupational Injuries and Illnesses.

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 31, 1993

Mr. Mike France
123 Francois Drive
Lafayette, Louisiana 70507

Dear Mr. France:

Location and maintenance of OSHA injury and illness records.

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.

September 10, 1993

Mr. David E. Jones
Ogletree, Deakins, Nash, Smoak & Stewart
3800 One Atlantic Center
1201 West Peachtree Street, N.W.
Atlanta, Georgia 30309

Dear Mr. Jones:

Thank you for your letter dated August 19, requesting an interpretation concerning the location and maintenance of OSHA injury and illness records. Guidance on the 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.

Counting lost workdays for temporary employees.

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.

September 20, 1993

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

Dear Mr. Wasser:

Thank you for your letter dated September 2, requesting an interpretation on counting lost workdays for temporary employees who suffer occupational injuries or illnesses. We find your analysis of the situation outlined in your letter to be correct. I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing the appropriate page and Q&A numbers.

Several bloodborne pathogen 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.

September 20, 1993

Mr. W. William Ament
Organization Resources Counselors, Inc.
1910 Sunderland Place, N.W.
Washington, D.C. 20036

Dear Mr. Ament:

Thank you for your letter dated July 30, requesting interpretations on several bloodborne pathogen issues as they relate to the OSHA injury and illness recordkeeping system. I will repeat each of your questions and follow with my response.

Recording criteria for recordkeeping cases involving occupational hearing loss.

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.

March 4, 2004

Mr. Carl O. Sall, CIH
Director of Occupational Safety
and Health Compliance
Comprehensive Health Services, Inc.
8229 Boone Boulevard, Suite 700
Vienna, VA 22182-2623

Dear Mr. Sall: