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OSHA interpretation · 1994-05-12

Completing the OSHA Supplementary Record 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.

May 12, 1994 Mr. Jerry A. Carter Safety Director Cerro Copper Products Company Post Office Box 66800 St. Louis, Missouri 63166-6800 Dear Mr. Carter: Thank you for your letter dated April 14, requesting clarification of the recordkeeping requirements pertaining to completing the OSHA Supplementary Record of Occupational Injuries and Illnesses (OSHA No. 101). I will restate each of your questions and follow with our response. Q1. Are the five (5) items listed in the Form OSHA 101 instructions the only items that are REQUIRED by regulation to be filled in? A1. The five items listed in the instructions of OSHA Form 101 refer to the sections on the front of the form. Each section has multiple questions. All of the items in each section are required to be completed. Q2. Is it a regulatory requirement that all blocks be filled in on Form OSHA 101? A2. Yes, all questions on the form must be addressed within 6 work days of learning of a recordable injury or illness. Q3. If it is not a requirement to fill in all the blanks, which ones may be left empty? Which ones filled in? A3. All items must be addressed. Q4. If all of the blanks must be filled in, is it acceptable to enter N/A or UNKNOWN in a block? A4. If the employer does not have sufficient information to answer the question within the 6 workday requirement, unknown may be entered in the block. However, the employer must investigate the case to obtain the information to complete the form in its entirety. Q5. What action should be taken if the required information is not available within the six day requirement to complete the form? A5. The employer should enter unknown in the blocks in question. When the employer does obtain additional information needed to complete the form, the form must be updated with that information. Q6. If an approved State workers' compensation form is used in lieu of the OSHA Form 101, do the same criteria , rules, and guidelines apply to the State workers' compensation form as the OSHA Form 101 for supplemental recordkeeping purposes? A6. If an alternative form is being used in lieu of the OSHA Form 101, the form must be completed using the OSHA recordkeeping regulations for each OSHA recordable injury or illness. The OSHA recordkeeping regulations apply only to recording injuries and illness for OSHA recordkeeping purposes. They have no effect on workers' compensation or other insurance systems. As found on page 18 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses , an alternative form may be used if it contains identical information to the OSHA Form 101. Furthermore, if the alternative record does not contain all the information of the OSHA Form 101, items can be supplemented by adding the missing items. I hope you find this information useful. If you have any questions, please contact my staff 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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