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OSHA interpretation · 1993-08-31

Proper recording on the OSHA Log of Occupational Injuries and Illnesses.

← 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.

August 31, 1993 Mr. Mike France 123 Francois Drive Lafayette, Louisiana 70507 Dear Mr. France: Thank you for your letter dated May 25, requesting an interpretation on the proper recording of two cases on the OSHA Log of Occupational Injuries and Illnesses (OSHA 200). Please excuse the lengthy delay in our response. Your letter was forwarded to my office by the Dallas Regional Office. My Division of Recordkeeping Requirements is responsible for the maintenance of the OSHA injury and illness recordkeeping system nationwide. Whenever possible, I will refer to the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the relevant page and Q&A numbers. Any days away or days of restricted work activity associated with the additional damage to the employee's knee caused by the "physical therapist malpractice" must be counted and applied to the original knee injury case. The affected employee would not have suffered these additional days but for the original occupational knee injury (see Q&A F-17, page 45). For the same reasoning, the case involving the employee's smashed thumb would be classified as a recordable fatality. The employee would not have suffered the adverse reaction to the medication but for the occupational injury. Please be aware that OSHA recordkeeping requirements differ from those established under various State workers' compensation laws. Workers' compensation criteria should not be substituted for OSHA definitions in determining whether or not a case should be recorded under the OSHA system. 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

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