- 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.
March 24, 1994
Mr. Michael D. Zoll, CSP
Manager of Safety
Alcan Aluminum Corporation
100 Erieview
Post Office Box 6977
Cleveland, Ohio 44101-1977
Dear Mr. Zoll:
Thank you for your letter dated February 8, requesting guidance on the proper recording of illnesses on the OSHA 200 Log. 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 recordkeeping purposes, an occupational illness is any abnormal condition or disorder resulting from a non-instantaneous event or exposure within the work environment. Any such job related abnormality reported to the employer is recordable, whether or not functional impairment is present or lost workdays are involved (see Q&As E-8 and E-9 on page 41 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).
An illness is considered work related if an exposure at work either caused or contributed to the onset of symptoms or aggravated existing symptoms to the point that they meet OSHA recordability criteria. Moreover, if it seems likely that an event or exposure within the work environment either contributed to or aggravated the condition, it is considered work related (see Q&A B-17, page 32 of the Recordkeeping Guidelines). Therefore, unless the illness was caused solely by a non-work related event or exposure off premises, the case is presumed to be work related. If the physician is able to say that an employee's lung scarring was in no way contributed to or aggravated by the dust exposure (or any other exposure) within the work environment, then the case would not be considered work related, and therefore not recordable. If the condition is determined to be recordable, the case(s) should be recorded as Dust Diseases of the Lungs, column 7(b) on the Log.
When recording occupational illnesses, enter the date of initial diagnosis or recognition of the illness, or, if absence from work occurred before diagnosis, enter the first day of absence attributable to the illness which was later diagnosed or detected (see page 9 of the Recordkeeping Guidelines).
If a work related illness is discovered within 5 years after the employee retires, the case should be recorded in the year of occurrence if the date of the onset of illness can be identified. If not, the case should be recorded in the retiree's last year of employment (see Q&A E-5, on page 23 of the Recordkeeping Guidelines).
I hope you find this information useful. If you have any further questions, please call us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements