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.
January 24, 1997
Mr. William K. Principe
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557
Dear Mr. Principe:
Thank you for your letter dated December 13, requesting an interpretation regarding the proper recording of an injury case involving a punctured eardrum that did not result in medical treatment or hearing loss. Because the injury did not impair the employee's normal use of senses, it should be treated as a minor injury. A minor injury which does not result in medical treatment, loss of consciousness, restriction of work or motion, or job transfer should not be recorded on the OSHA Log.
I hope you find this information helpful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements