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Pencil entries and corrections on OSHA injury logs

Summary An employer asked whether it could use pencil and correction fluid on OSHA's injury and illness log. OSHA said either was acceptable under its then-current rules if the records remained legible, complete, and accurate. OSHA archives the letter and warns that it may no longer reflect current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1992-02-25-0
Date issued
February 25, 1992
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 25, 1992

Ms Felicia J. Bayer
Bristol-Myers
Squibb Pharmaceutical Research Institute
[Recipient address omitted]
Dear Ms. Bayer:

Thank you for your letter of February 10, requesting clarification of the OSHA injury and illness recordkeeping requirements. Your questions are 1) is pencil acceptable in completing the OSHA 200 Log, and 2) can white-out be used for corrections on the 200 Log.

It is acceptable to fill out the OSHA injury and illness records (OSHA 200 and 101) with a pencil, pen, typewriter or any other media you wish to use. You may also use correction fluid or any other technique of entry removal that you desire.

The main issue is not the writing instrument used to maintain the injury and illness records but rather that the records be legible, complete and accurate. Any medium that allows you to easily update the records as new and more exact information is obtained may help one to meet their maintenance obligations.

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,
Stephen A. Newell
Acting Director
Office of Statistics

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