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Which year to log a delayed audiogram report

Summary A steel company asked which year’s OSHA 200 log should show a December audiogram whose report arrived in January. OSHA said a recordable case belonged on the log for the year the test was performed, which it treated as the initial diagnosis date. OSHA labels the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-08-30-0
Date issued
August 30, 1991
Status
Archived by the agency
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Hearing Conservation
Source
View the official document

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The current status of this document is unclear
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 30, 1991

J. J. Schwerha, M.D.
General Manager - Health Services and Medical Director
United States Steel
[Recipient address omitted]

Dear Dr. Schwerha:

Thank you for your letter of July 10, 1991 requesting clarification of the OSHA injury and illness recordkeeping requirements for occupational hearing loss cases.

Your letter describes a situation where an audiogram is done in December 1990, but the report is not received from the vendor until January 1991. If the case meets the criteria for recording on the OSHA 200 Log, then the case should be entered on the 1990 Log. Our interpretation is that the date of the audiogram is also the date of the initial diagnosis of illness.

I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463.

Sincerely Yours,
Stephen A. Newell
Acting Director
Office of Statistics

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