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Recording instantaneous friction blisters

Summary An employer asked whether an instantaneous work-related friction blister had to be recorded if it needed no medical treatment or work restriction. OSHA treated the instantaneous event as an injury under its former guidelines and said the described case was not recordable. OSHA labels the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1999-02-17
Date issued
February 17, 1999
Status
Archived by the agency
OSHA labels this letter an archive document that may no longer represent OSHA policy; it applies the former injury and illness recording guidance.
Status last verified October 9, 2026

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The current status of this document is unclear
OSHA labels this letter an archive document that may no longer represent OSHA policy; it applies the former injury and illness recording guidance. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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OSHA archive notice: "This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only."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 17, 1999

Michele J. Elliott
Safety Coordinator
Tenneco Packaging
[Recipient address omitted]

Dear Ms. Elliott:

Thank you for your faxed letter, dated October 22, 1998, requesting a written response to the following question, "Is an instantaneous friction blister recordable if it does not require medical treatment or result in restrictions?" Please excuse the delay in our response. I will answer your question by citing the Recordkeeping Guidelines for Occupational Injuries and Illnesses wherever possible.

Section D on Page 37 of the Recordkeeping Guidelines deals with the distinction between injuries and illnesses for recordkeeping purposes. Whether a case involves an injury or illness is determined by the nature of the original event or exposure which caused the case, not by the resulting condition of the affected employee. Injuries are caused by instantaneous events in the work environment. Cases resulting from anything other than instantaneous events are considered illnesses. Historically, "instantaneous" has been defined as a snap of the fingers.

A friction blister which resulted from an instantaneous event is evaluated as an injury for recordkeeping purposes. If it did not involve medical treatment, loss of consciousness, restriction of work or motion or transfer to another job, then the case is not to be recorded.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202) 693-1702.

Sincerely,

Cheryle A. Greenaugh
Director, Directorate of Information Technology

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