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Historical recurrence rule for cumulative trauma cases

Summary A meatpacking company asked when a cumulative trauma disorder case was resolved for OSHA 200 recordkeeping. OSHA said complete resolution of signs and symptoms for 30 days ended the case; recurrence within that period could continue the earlier case. OSHA labels this historical letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-09-17
Date issued
September 17, 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This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.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 Ergonomics
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This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 17, 1991

Mr. Richard A. Jochum
Counsel
IBP Incorporated
[Recipient address omitted]

Dear Mr. Jochum:

Thank you for your letter of August 28 requesting a written clarification of appropriate recordkeeping practice for CTD case resolution and symptom recurrence.

This letter is to verify as stated in the Ergonomics Program Management Guidelines For Meatpacking Plants, 1990, that a case is considered to be complete once there is complete resolution of signs and symptoms for a thirty day period. If complaints reoccur within that thirty day period, you may consider it a continuation of a previous case rather than a new case.

If you have any questions or comments please contact Bob Whitmore of my office at (202) 523-1463.

Sincerely,
STEPHEN A. NEWELL
ACTING DIRECTOR
OFFICE OF STATISTICS

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