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Recording a punctured eardrum without treatment or lost work

Summary An attorney asked whether a work-related punctured eardrum had to be logged when it caused no medical treatment or hearing loss. OSHA said that, under its then-current criteria, an injury with no impairment of normal senses was minor and was not recordable unless it led to treatment, unconsciousness, restricted work, or job transfer. OSHA now archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-01-24
Date issued
January 24, 1997
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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 24, 1997
Mr. William K. Principe
Constangy, Brooks & Smith
[Recipient address omitted]
Dear Mr. Principe:
Thank you for your letter dated December 13, requesting an interpretation regarding the proper recording of an injury case involving a punctured eardrum that did not result in medical treatment or hearing loss. Because the injury did not impair the employee's normal use of senses, it should be treated as a minor injury. A minor injury which does not result in medical treatment, loss of consciousness, restriction of work or motion, or job transfer should not be recorded on the OSHA Log.
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

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