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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

January 13, 1994

MEMORANDUM FOR:     REGIONAL ADMINISTRATORS

ATTENTION:          REGIONAL RECORDKEEPING COORDINATORS

THRU:               LEO CAREY Director
                   Office of Field Programs

FROM:               BOB WHITMORE Chief, Division of
                   Recordkeeping Requirements Office of Statistics

SUBJECT:            Recording Bloodborne related cases on the OSHA 200 Log

Work Relationship

Proper recording of a bloodborne pathogens case.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 31, 1994

Mr. William K. Principe
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Thank you for your letter dated December 3, requesting an interpretation regarding the proper recording of a bloodborne pathogens case on the OSHA Log 200. The case as outlined in your letter is a recordable case on the OSHA log.

Recordability of a fatal traffic accident in a foreign project location.

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, 2004

Mr. John A. Dempsey, Jr.
Vice President
PFD International LLC
One Fluor Daniel Drive
Sugarland, TX 77478

Dear Mr. Dempsey:

We in OSHA's Directorate of Evaluation and Analysis are responding to your letter dated Friday, April 16, 2004 in which you request guidance on the proper recordability classification of a recent motor vehicle fatality that occurred in one of your foreign project locations.

Recording audiogram test results on 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 30, 1991

J. J. Schwerha, M.D.
General Manager - Health Services and Medical Director
United States Steel
600 Grant Street
Pittsburgh, Pennsylvania 15219

Dear Dr. Schwerha:

Thank you for your letter of July 10, 1991 requesting clarification of the OSHA injury and illness recordkeeping requirements for occupational hearing loss cases.

Use of glue to close a wound is medical treatment; prescription antibiotics/antiseptics for preventive treatment of a wound is medical treatment.

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, 2004

Mr. Ronald Bjork
Manager, Safety, Health & Security
CNH America LLC
East Moline Plant
1100 Third Street
East Moline, IL 61244

Dear Mr. Bjork:

This is in response to your letter of April 21, 2004 requesting clarification whether two types of treatments constitute first aid or medical treatment for purposes of applying OSHA's recordkeeping rule.

Determination of a case as days away or restricted work; case must be recorded in manner reflecting what actually occurs.

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, 2006

Ms. Linda Ballas & Associates
4413 Copper Creek Lane
Toledo, Ohio 43615

Dear Ms. Ballas:

This is in response to your letter dated March 7, 2005. In your letter, you presented the scenario listed below and requested clarification of how it should be recorded on the OSHA Form 300.

Clarification on recording days away from work for follow-up visits to doctor while on restricted-duty job and recovery time to stabilize preexisting condition.

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.

November 30, 2005

Chris Korleski
Honda of America Mfg., Inc
2400 Honda Parkway
Marysville, OH 43040-9251

Dear Chris Korleski:

Thank you for your letter dated June 21, 2005 in which you request our guidance on the proper recordability of two workplace injuries to insure that you are consistent with the OSHA Injury and Illness Recordkeeping regulation, 29 CFR Part 1904, and its application to the OSHA 300 log.

Once medical treatment beyond first aid has occurred for injury or illness the case must be recorded.

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.

November 15, 2005

Mr. Steve M. Olson
Vice President, Safety and Training
Nabors Well Services Ltd.
515 West Greens Rd., Suite 1170
Houston, TX 77067

Dear Mr. Olson:

Employer obligation to provide access to entire OSHA 300 Logs, including names of both union and non-union employees.

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 9, 2005

Mr. Thomas D. O'Connor
National Labor Relations Board
Division of Advice - 10th Floor
1099 14th Street, NW
Washington, DC 20005

Dear Mr. O'Connor:

29 CFR Part 1904 OSHA Recordkeeping Regulation applies only within the jurisdictional boundaries of the United States and certain locations listed in OSHAct Sec. 4(a).

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 1, 2005

Mr. Roy Kader

Health, Safety and Environment Manager
JGC Corporation
P.O. Box 422, Falaj Al-Qabail
Postal Code-322
Sohar, Sultanate of Oman

Dear Mr. Kader: