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OSHA interpretation · 1991-08-30

Recordkeeping requirements for injury cases which result in treatment with prescription medications.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

August 30, 1991 Ms. Linda Balas Environmental Management and Training Systems, Inc. 4413 Copper Creek Lane Toledo, Ohio 43615 Dear Linda: Thank you for your letter of July 29 requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medications. As stated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illness , medical treatment includes "Use of PRESCRIPTION MEDICATIONS (except a single dose administered on first visit for minor injury or discomfort)". The case you describe in your letter resulted in the use of 1) a single dose of prescription eye drops employed as a local anesthetic and 2) a single dose of prescription eye drops used to treat/prevent infection. The treatment of this injury clearly involved the use of two doses of prescription medication and is therefore considered medical treatment for OSHA recordkeeping purposes. I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463. Sincerely, Stephen A. Newell Acting Director Office of Statistics

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.