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OSHA interpretation · 1996-09-20

A reevaluation of recording injuries and illnesses associated with voluntary flu shot programs 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.

September 20, 1996 Mr. Larry M. Kreh Manager, Ergonomics and Loss Prevention PPG Industries, Inc. Post Office Box 2009 Allison Park, Pennsylvania 15101 Dear Mr. Kreh: Thank you for your letter requesting a reevaluation of recording injuries and illnesses associated with voluntary flu shot programs on the OSHA Log and Summary of Occupational Injuries and Illnesses. As you are aware, OSHA is in the process of revising its occupational injury and illness recordkeeping requirements. In a Notice of Proposed Rulemaking published in the February 2, 1996 Federal Register, OSHA proposed to discontinue the requirement to record the very cases from which you are requesting an exception. OSHA believes it will not lose any valuable information through the discontinuation of recording these particular cases and sees no need to delay this policy until publication of a final rule. Therefore, we are revising our interpretation and do not consider injuries and illnesses which solely result from the voluntary flu shot programs on the employers premises to be work related. These cases are therefore no longer recordable. 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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