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Updating the OSHA injury and illness log summary

Summary An attorney asked whether employers had to update the summary section of an OSHA injury and illness log. OSHA said two parts of its then-current guidelines conflicted, so it interpreted the rules as not requiring an updated summary, though it encouraged updates. OSHA now labels this an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-03-05
Date issued
March 5, 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OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 5, 1997
Mr. William K. Principe
Constangy, Brooks & Smith
[Recipient address omitted]
Dear Mr. Principe:
Thank you for your letter dated February 13, requesting an interpretation regarding the requirement to update the OSHA Log and Summary of Occupational Injuries and Illnesses. Question B-13 on page 16 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses is in contradiction to Section E. on page 23 of the Guidelines in terms of an employer's responsibility to update the summary section of the Log. Because of this discrepancy, we have made the interpretation that employers are not required to update the summary. However, we do encourage them to do so.
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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