Job13
Sign inCheck a case

OSHA interpretation · 1993-04-02

Proper recording of a hepatitis A exposure for OSHA injury and illness recordkeeping purposes.

← 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.

April 2, 1993 Ms. Jeanette Rauba Safety Administrative Assistant AT&T 600 Mountain Avenue Post Office Box 636 Murray Hill, New Jersey 07974-0636 Dear Ms. Rauba: Thank you for your letter dated January 29, requesting an interpretation regarding the proper recording of a Hepatitis A exposure incident, for OSHA injury and illness recordkeeping purposes. Please excuse the lengthy delay in our response. I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses in my response. Recent guidance has been released regarding the proper recording of Hepatitis B (serum hepatitis) and other bloodborne pathogens. This guidance includes recording exposure incidents that result in medical treatment as found on the enclosed page 6 from CPL 2- 2.44c. However, Hepatitis A (infectious hepatitis) does not fall into this category. For proper recording procedure, we must refer to the Guidelines. The OSHA injury and illness recordkeeping system is not designed to record exposure incidents. Q&A B-6 on page 30 states "Entries on the log...should be made only when the exposure results in a recordable work injury or illness ." What must be determined is whether the employees have developed an abnormal condition (i.e. Hepatitis A infection or disease) as a result of the exposure. Furthermore, Q&A B-9 on page 30 addresses the situation of receiving preventative care when not injured or ill. This care does not make a case recordable. If your employees did not develop Hepatitis A infection or disease, the case should not be recorded. If, however, they did develop the infection or disease at a later date, record the case using the date of exposure. (This is assuming the restaurant workers were infected. Your letter states that they were " being tested ". Be aware that Hepatitis A has a short incubation period ranging from 2 to 6 weeks. You should have known fairly quickly if your employees developed the Hepatitis A infection from the exposure in question.) I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463. Sincerely, Stephen A. Newell 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

Deciding a case of your own?

The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

Check a case — free

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.