Evaluation of seven scenarios for work-relatedness and recordkeeping requirements.

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 15, 2004

Ms. Leann M. Johnson-Koch
1200 Nineteenth Street, N.W.
Washington, D.C. 20036-2412

Dear Ms. Johnson-Koch:

Determining work-relatedness when the work event or exposure is only one of the discernable causes; not the sole or predominant cause.

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, 2004

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

Dear Mr. Principe:

Thank you for your comments pertaining to the Occupational Safety and Health Administration's (OSHA) Injury and Illness Recording and Reporting requirements contained in 29 CFR Part 1904. Please accept my apology for the delay in our response.

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:

Determination of work-relatedness on a construction site.

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 12, 2006

Ms. Donna Cale
Cale Consulting
7408 Franklin Parke Court
Indianapolis, IN 46259

Dear Ms. Cale:

Whether to record injuries that occur to a contract employee when traveling from an offshore manned platform complex to other downfield fixed platforms.

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.

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

Mr. Jack Amberg
BP America
200 Westlake Park Blvd.
Room 02027
Houston, TX 77079

Dear Mr. Amberg:

Whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms.

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.

February 6, 2007

Mr. Brandon Muffoletto
3508 Curtis Lane
PO Box 9406
New Iberia, LA 70562-9406

Dear Mr. Muffoletto:

Thank you for your March 24, 2006 letter concerning the Occupational Safety and Health Administration's (OSHA's) injury and illness recordkeeping requirements of 29 CFR Part 1904. You requested specific guidance on whether to record injuries that occur to employees who travel from an offshore manned platform complex or dock to other offshore platforms.

Clarification of the terms most authoritative and pre-existing conditions as used 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.

February 25, 2011

Mr. William K. Principe
Constangy Brooks & Smith, LLP
Suite 2400
230 Peachtree Street, NW
Atlanta, GA 30303

Dear Mr. Principe:

Clarification of 1910.95 and 1904 regarding physicians and audiologists roles in determining work-relatedness of worker 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.

August 29, 2007

Theresa Y. Schulz, PhD
VA Medical Center, James H. Quillen
P.O. Box 344
Fall Branch, TN 37656

Dear Dr. Schulz:

Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness.

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, 2008

Mr. Neil H. Wasser
Constangy, Brooks & Smith, LLC
Suite 2400
230 Peachtree Street, NW
Atlanta, GA 30303-1557

Dear Mr. Wasser:

Whether to record two cases of employee injuries sustained in company parking lot during employees commute 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.

This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.

 

July 14, 2008

Ms. Lori A. Vaught, Manager
WSRC Health and Safety
ESH&QA & Performance Assurance
Savannah River Site
Aiken, SC 29808

Dear Ms. Vaught: