Determining work-relatedness for injuries in the home when telecommuting

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 30, 2009

Mr. C. D. Pinkerton
Safety Director
Dixon Electrical Systems & Contracting, Inc.
3352 Norwood Road
Huntington, WV  25705

Dear Mr. Pinkerton:

Clarification on whether an exercise regime is first aid or 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.

May 20, 2011

Mr. Paul Bragenzer
1415 Rothbury Dr.
Grand Rapids, MI 49505

Dear Mr. Bragenzer:

Clarification on recordability when trigger point injections are used for medical treatment and for diagnostic procedures

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 18, 2011

Dr. Jay Alexius
All Industrial Medical Services
855 Belanger Street Suite 207
Houma, LA  70360

Dear Dr. Alexius:

Clarification on pre-existing conditions and recordable incidents

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 5, 2010

Mr. Corby Autin
President
A&E Compliance Solutions, LLC
P.O. Box 475
Galliano, LA  70354

Dear Mr. Autin:

Determining work-relatedness for injury that occurred in company parking lot

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, 2010

Mr. Kenneth M. Colonna
RSC Equipment Rental
6929 East Greenway Parkway, Suite 200
Scottsdale, Arizona  85254

Dear Mr. Colonna:

Clarification of the term abnormal condition as used in the Recordkeeping standard

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 25, 2010

Mr. Eric Blankenheim, OTR, MSIE, CPE, CSP
Occupational Therapist
Blankenheim Services
1650 Tri-Park Way, Suite A
Appleton, WI  54914

Dear Mr. Blankenheim:

Recording an absence as days away when PLHCP recommends the employee return to work.

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 22, 2011

Mr. William K. Principe
Suite 2400
230 Peachtree St., NW
Atlanta, Georgia 3030-1557

Dear Mr. Principe,

Clarification on most authoritative when multiple medical opinions are provided.

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 24, 2010

Ms. Sandra V. Ohlson
Boston Scientific Corporation
47900 Bayside Parkway
Fremont, CA 94538

Dear Ms. Ohlson:

Therapeutic exercise is considered medical treatment for recordkeeping purposes.

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 21, 2010

Dr. Betsy Buehrer
3M Corporate Occupational Medicine
3M Center
Building 220-6W-08
St. Paul, Minnesota 55133-3428

Mr. Michael Nash
3M General Counsel
3M Center
P.O. Box 33428
St. Paul Minnesota 55133-3428

Dear Dr. Buehrer and Mr. Nash,

Recording days away and/or restricted work activity when employee is able to work part of a shift.

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 7, 2010

Ms. Linda Ballas
Linda Ballas & Associates
7129 Nightingale Drive
Holland, OH 43528

Dear Ms. Ballas: