Ezel / Labor Guidance / US
Back to Federal guidance

Historical reporting of multiple hospitalizations

Summary A lawyer asked how OSHA’s then-current fatality and multiple-hospitalization reporting rule counted workers from different employers. OSHA confirmed that the duty applied to an employer’s own employees and workers it supervised day to day, including full- and part-time workers. OSHA archives the letter and warns it may no longer state current policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-05-26-0
Date issued
May 26, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy; the letter interprets the reporting rule then in effect.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Incident Reporting Recordkeeping
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

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OSHA labels this an archive document and warns that it may no longer represent current policy; the letter interprets the reporting rule then in effect.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 26, 1994

Mr. Lawrence P. Halprin
Keller and Heckman
[Recipient address omitted]
Dear Mr. Halprin:

Thank you for your letter dated April 21, requesting clarification on the revised requirements for reporting occupational fatalities and multiple hospitalization incidents to OSHA.

Your interpretation of the revised requirements, as outlined in your letter is correct. The reporting requirements apply only to the in-patient hospitalization or death of employees of an employer. Employees include all full and part-time employees. In addition, all workers who are supervised on a day-to-day basis by a given employer are considered employees of the using firm for recording and reporting purposes.

I hope you find this information useful. If you have any further questions, please contact us at Area Code: (202) 219-6463.

Sincerely,
Stephen A. Newell
Director
Office of Statistics

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

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace