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OSHA interpretation · 1991-09-17

Appropriate recordkeeping for CTD case resolution and symptom recurrence.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

September 17, 1991 Mr. Richard A. Jochum Counsel IBP Incorporated Dakota City, Nebraska 68731 Dear Mr. Jochum: Thank you for your letter of August 28 requesting a written clarification of appropriate recordkeeping practice for CTD case resolution and symptom recurrence. This letter is to verify as stated in the Ergonomics Program Management Guidelines For Meatpacking Plants , 1990, that a case is considered to be complete once there is complete resolution of signs and symptoms for a thirty day period. If complaints reoccur within that thirty day period, you may consider it a continuation of a previous case rather than a new case. If you have any questions or comments please contact Bob Whitmore of my office at (202) 523-1463. Sincerely, STEPHEN A. NEWELL ACTING DIRECTOR OFFICE OF STATISTICS

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.