Recording hearing loss when an employee works at multiple establishments

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 6, 1993

MEMORANDUM FOR: GILBERT J. SAULTER
Regional Administrator, Region VI

ATTENTION: JEFF RUCKER
Regional Recordkeeping Coordinator

THRU: LEO CAREY Director Office of Field Operations

FROM: STEPHEN A. NEWELL Director Office of Statistics

SUBJECT: Recordkeeping Interpretation - Hoechst Celanese Corporation

Thank you for your memorandum dated November 19, requesting an interpretation for the proper recording of a case of hearing loss on the OSHA Log 200. When an employee works at multiple sites of the same corporation, an injury or illness should be recorded on the Log of the establishment where the accident or illness exposure occurred. Regarding the situation described in the letter from Mr. Whitmer of the Hoechst Celanese Corporation, because the consulting audiologist, Dean A. Harris, Ph.D., is able to say that 100% of the employee's hearing loss occurred at the Pampa plant, the case should be recorded on the Log of the Pampa Plant (and lined out on the Log in Corpus Christi). The case should be entered using the last date the employee was at that particular location (the last date of exposure). Also, please notify Mr. Whitmer that hearing loss should be recorded as a column 7(f) case, Disorders Associated with Repeated Trauma, not column 7(e). If you have any questions, please contact Bob Whitmore of my staff at Area Code (202) 219-6463.

[Requester correspondence reproduced on OSHA page; omitted here.]