Job13

OSHA interpretation · 1993-05-24

Proper recording of work related burns on the OSHA 200 log.

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.

May 24, 1993 Mr. David E. Jones Ogletree, Deakins, Nash, Smoak & Stewart 3800 One Atlantic Center 1201 West Peachtree Street, N.W. Atlanta, Georgia 30309 Dear Mr. Jones: Thank you for your letter dated March 8, requesting an interpretation on the proper recording of work related burns on the OSHA 200 Log. Whenever possible, I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing page and Q&A numbers. Non-pinhead work related second degree burns and all occupational third degree burns are recordable, regardless of the type of treatment given. Work related pin-head sized second degree burns and first degree burns are recordable if they involve loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment. As stated on page 42 of the Guidelines, the use of non-prescription medications is considered first aid for injury and illness recordkeeping purposes. Since you state that WaterJel is non-prescription, its use is considered to be first aid. Regarding the use of antiseptics on second and subsequent visits to medical personnel, our current position and interpretation is as follows: If the use of antiseptics on second or subsequent visits is the only criterion for making a case recordable, the case should not be recorded unless the antiseptic involved is one that requires a prescription in order to obtain it and it is used beyond a single dose. The recordability would then be based on our guidelines for the use of prescription medication as medical treatment. I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463. Sincerely, Stephen A. Newell 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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The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

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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.