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Former cumulative trauma disorder case protocol

Summary OSHA reviewed an employer's proposed criteria for new, recordable, and closed work-related cumulative trauma disorder cases and said applying them would comply with then-current injury recordkeeping rules. The posted page includes the criteria. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1994-12-07-0
Date issued
December 7, 1994
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent current policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent current policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 7, 1994

Patrick J. Beecher, MD
Associate Medical Director, Ford Motor Company
[Recipient address omitted]
Dear Dr. Beecher:

Thank you for your letter dated November 23, requesting our review of your recording protocol for work related cumulative trauma disorder cases. Upon review, we find your criteria for defining a "New CTD Case", a "Recordable CTD Case" and a "Closed CTD Case" consistent with our interpretations. When applying these recording criteria to work related CTD cases, you will be in compliance with our current injury and illness recordkeeping requirements.

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

Sincerely,

Bob Whitmore Chief Division of Recordkeeping Requirements

Definition of a New CTD Case

A new CTD case is established when:

  • an employee reports signs and/or symptoms related to a new exposure in the workplace for which there is no open case for the same body part, or

  • an employee reports signs and/or symptoms related to a CTD case which has been closed.

Definition of a Recordable CTD Case

A CTD case is recordable if either of the following criteria apply:

  • The presence of one or more abnormal physical finding(s), ie., objective sign(s); or

  • The presence of subjective symptom(s) coupled with either medical treatment, as defined by OSHA, or lost workday(s), ie., days away from work and/or restricted work activity (including transfer or rotation to another job).

Definition of a Closed CTD Case

A CTD case is closed if either of the following criteria apply:

  • 30 calendar days have passed since a medical evaluation established complete resolution of signs and symptoms (regardless of ongoing treatment or lost work days) or

  • 30 days have passed since the employee received any medical treatment as defined by OSHA for the CTD case, and the employee has been returned to regular work or placed on a permanent restriction as a result of the CTD.

When a case meets the definition of a "closed case" as stated above and a medical evaluation occurs as a result of a scheduled medical follow-up, and all four of the following conditions are met the visit shall not create a new case for OSHA Recordkeeping purposes.

  • no worsening of objective signs and/or symptoms,

  • no indication for a new temporary restriction,

  • no change to the permanent restriction(s) is made or the permanent restriction(s) is made less restrictive, and

  • no change in medical treatment prescribed.

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