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OSHA interpretation · 1995-08-07

The proper recording of illness cases on the OSHA Log and Summary 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 7, 1995 Mr. James F. Smith Mountain Technical Center 10100 West Ute Avenue Post Office Box 625005 Littleton, Colorado 80162-5005 Dear Mr. Smith: Thank you for your letter dated June 27, requesting an interpretation regarding the proper recording of illness cases on the OSHA Log and Summary of Occupational Injuries and Illnesses. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide. For OSHA injury and illness recordkeeping purposes, an occupational illness is defined as an abnormal health condition caused or contributed to by a non-instantaneous event or exposure in the work environment. All occupational illnesses, no matter how transient or short lasted, are recordable. Subjective symptoms such as the feeling of malaise, headache or nausea are not recordable if there is no apparent association with the work environment. However, subjective complaints which are occupational in origin and attributable to non-instantaneous events or exposures must be recorded on the OSHA Log (see Q&A E-16 on page 42 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses ). Please be aware that OSHA is currently in the process of revising its injury and illness recordkeeping requirements. In doing so, we are proposing to revise the recording criteria to capture more serious cases and not those which only involve short lived minor signs or symptoms. We anticipate publishing the proposed revision in the Federal Register this summer. I look forward to receiving any comments you may have regarding this matter at that time. I hope you find this information useful. If you have any further questions, 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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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.