Standard Interpretations - Table of Contents
• Standard Number: 1904.4(a); 1904.46

January 25, 2010

Mr. Eric Blankenheim, OTR, MSIE, CPE, CSP
Occupational Therapist
Blankenheim Services
1650 Tri-Park Way, Suite A
Appleton, WI 54914

Dear Mr. Blankenheim:

Thank you for your June 19, 2009 letter to the Occupational Safety and Health Administration (OSHA) regarding the Recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. In an effort to provide interested persons with prompt and accurate responses to their inquiries about the Recordkeeping regulation, we continue to develop and refine a set of (Frequently Asked Questions) as well as maintaining a log of Letters of Interpretations, all of which are on the Recordkeeping page on OSHA's web site at

Your letter requests clarification of the term "abnormal condition" in the Recordkeeping regulation's definition of injury or illness and the role of health care professionals in evaluating whether an injury or illness has occurred.

Question 1: Is muscle soreness resulting from a new activity considered an "abnormal condition?"

Answer: Section 1904.4(a) of OSHA's Recordkeeping regulation provides that each employer who is required to keep occupational injury and illness records must record each case that:

  1. Meets the regulation's definition of "injury or illness;"
  2. Is work-related;
  3. Is a new case and not a continuation of an old case; and
  4. Meets one or more or the general recording criteria in section 1904.7 (e.g., days away from work, restricted work or job transfe