Recording clinically diagnosed cumulative trauma disorders

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 22, 1995
Mr. Mitchell S. Allen, Constangy
Brooks & Smith
[Recipient address omitted]
Dear Mr. Allen:
Thank you for your letter dated January 23, requesting an interpretation concerning the proper recording of cumulative trauma disorders (CTDs) for OSHA injury and illness recordkeeping purposes. When a specific medical condition (e.g. carpal tunnel syndrome, tenosynovitis, epicondylitis, etc.) is clinically diagnosed and determined to by work related, the case must be recorded on the OSHA Log regardless of whether medical treatment, job restrictions or days away were involved. Such a clinical diagnosis should be considered an objective finding. If, however, the medical condition is categorized in general terms such as a "strain", the employer must evaluate the case for objective findings, medical treatment, job restrictions or days away to determine its recordability.
I hope you find this information helpful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Sincerely,
Bob Whitmore Chief Division of Recordkeeping Requirements