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OSHA interpretation · 1993-11-29

What is considered medical treatment.

← 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.

November 29, 1993 Ms. Eileen Rosenkoetter Director of Employee Health Association of Hospital Employee Health Nurses of Greater St. Louis St. Joseph Hospital 525 Couch Avenue Kirkwood, Missouri 63122 Dear Ms. Rosenkoetter: Thank you for your letter dated November 1, requesting an interpretation regarding what is considered medical treatment for OSHA injury and illness recordkeeping purposes. As found in Section F. on page 42 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses , examinations or other diagnostic procedures to determine whether an employee has an injury or is ill do not constitute medical treatment. Therefore, HIV testing and HBV antibody testing are not considered medical treatment. "Counseling" associated with occupational bloodborne exposures is also not considered medical treatment (though counseling for related mental stress may be considered medical treatment). Medical treatment involves the provision of medical or surgical care for injuries through the application of procedures or systematic therapeutic measures. Generally, the draining of blood or bodily fluids is considered medical treatment for OSHA injury and illness recordkeeping purposes when preformed as a treatment rather than as a diagnostic procedure. Taking blood simply for testing purposes is not considered medical treatment. The evaluation of medical treatment versus first aid does not depend on the availability of the treatment or the status of the source patient. Under 29 CFR 1904, medical treatment includes treatment that is actually provided as well as treatment that is clearly required but not provided. Thus, recommended treatment need not be rendered to satisfy the recordability criteria. This is consistent with the recordkeeping practices relating to cases other than those involving bloodborne pathogens. This guidance can be found on page 44 of the Recordkeeping Guidelines, Q & A F-5. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief 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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