- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.
June 4, 1991
MEMORANDUM FOR: REGIONAL ADMINISTRATORS
THRU: LEO CAREY
Director
Office of Field Programs
FROM: PATRICIA CLARK
Director
Directorate of Compliance Programs
STEPHEN NEWELL
Director
Office of Statistics
SUBJECT: RECORDING OF HEARING LOSS AND CUMULATIVE TRAUMA
DISORDERS (CTDS) ON THE OSHA 200 LOG
Two injury and illness recordkeeping issues, occupational hearing loss and cumulative trauma disorders, have received national attention and require immediate clarification. This memorandum provides the current Agency position on these two conditions to OSHA's field staff. The upcoming revision of the recordkeeping regulations, guidelines and related instructional materials will address the recordability criteria for all work related injuries and illnesses. Please distribute this guidance to all OSHA offices, State plan designees and consultation programs in your region.
These decisions are being issued to improve the consistency of the information captured on the OSHA logs. Both of these clarifications are based on the current recordkeeping regulations and the supplemental instructions to the forms, the Recordkeeping Guidelines for Occupational Injuries and Illnesses.
The current guidelines provide clear criteria for recording these conditions if they result from instantaneous events (i.e., these are considered injuries and are recorded when they result in medical treatment, loss of consciousness, restriction of work or motion, or transfer to another job).
However, most cases of occupational hearing loss are cumulative trauma disorder result from exposures that are not instantaneous, and are considered occupational illnesses. The current guidelines and instructions on the back of the OSHA 200 log define recordable occupational illnesses as any abnormal condition or disorder. These are work related if an exposure in the work environment either caused, aggravated or contributed to the case. Some employers and others are unsure about what constitutes an abnormal condition or disorder for these conditions. As a result, the following criteria have been developed:
Hearing Loss:
OSHA will issue citations to employers for failing to record work related shifts in hearing of an average of 25 dB or more at 2000, 3000, and 4000 hertz (Hz) in either ear on the OSHA 200 log.
Employers are presently required by 29 CFR 1910.95 to inform employees in writing within 21 days of the determination of a Standard Threshold Shift (an average of 10 dB or more at 2000, 3000 and 4000 Hz in either ear) and to conduct specific follow-up procedures as required in paragraph (g) of the standard. Employers should be encouraged to use this information as a tracking tool for focusing noise reduction and hearing protection efforts.
Upper Extremity Cumulative Trauma Disorders (CTDs): (excludes back cases)
OSHA will issue citations to employers for failing to record work related CTDs on the OSHA 200 log that are evidenced by:
* at least one physical finding, (i.e., an objective symptom);
* a subjective symptom coupled with either medical treatment or lost workdays, (i.e., days away from work and/or days of restricted work activity).