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OSHA interpretation · 1993-10-26

Proper recording procedure for illnesses contracted outside of the United States.

← 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.

October 26, 1993 Ms. Lyn E. Lang Safety Systems Administrator Aluminum Company of America ALCOA Building Pittsburgh, Pennsylvania 15219 Dear Ms. Lang: Thank you for your letter dated September 23, requesting an interpretation for the proper recording procedure for illnesses contracted outside of the United States. Q&A A-12 on page 4 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses best addresses this situation. Records need not be kept for employees when they are outside the geographic scope of coverage prescribed by Section 4(a) of the Act. Neither case described in your letter would be recordable, as long as the illness exposure occurred outside of the United States and it's territories. More specifically, the second scenario may be treated in the same fashion as symptoms that merely surface on the employers premises, but are the result of a non-work related event or exposure off premises (see Q&A C-8 on page 34 of the Guidelines). I hope you find this information useful. If you have any further questions or comments, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

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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