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OSHA interpretation · 1992-07-02

Medical treatment recording on OSHA 200 log.

← 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.

July 2, 1992 Donald L. Berling, M.D. Plant Physician Mead Paper Post Office Box 2500 Chillicothe, Ohio 45601-2500 Dear Dr. Berling: Thank you for your letter dated April 14 requesting an interpretation on recording eye injuries on the OSHA 200 Log. Please excuse the delay in our response. We commend your practice of precautionary treatment of eye injuries and encourage a proactive approach to the prevention of minor injuries developing into more serious conditions. However, for the purpose of keeping the OSHA injury and illness recordkeeping system as simple and equitable as possible, we require that any work related injury requiring prescription medication (except a single dose administered on first visit for minor injury or discomfort) be recorded on the OSHA 200 Log. Thus, any prescription medicine actually provided regardless of the purpose for which it is given, is considered medical treatment (please see page 44 Q & A F-5 in the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses ). Following the supplemental instructions as presented in the Guidelines leads to consistent, useful records nationwide. If you have any further questions or comments, please contact my staff at (202) 523-1463. Sincerely, STEPHEN A. NEWELL Acting Director Office of Statistics Enclosure April 14, 1992 Steve Newell Acting Director of Statistics Department of Labor 200 Constitution Ave. N.W. Room 3507 Washington D.C. 20210 Dear Mr. Newell, Oftentimes treatment with eye preparations, such as Erythromycin or topical Sulfa preparations are used in a prophylactic manner, even though the injury itself may be minimal. Application of topical antibiotics is fairly standard treatment for even the most trivial eye injury, like minor abrasions or conjunctivitis of various types. Certainly the opposite approach, i.e., not applying antibiotic preparations to prevent the injury from being recordable, could prove to be most costly in terms of producing an adverse result. Therefore, we ask that every eye we treat with two or more applications of a prescription ointment should not automatically be OSHA recordable. We would carefully examine each incident and make the determination according to the history, the severity of the injury and whether it is truly treatment or used as a preventive measure. Thank you for your consideration of this matter. Donald L. Berling, M.D. Plant Physician James Segelhorst Plant Safety Shirley Pigott, R.N. Nurse Supervisor

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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