Job13

OSHA interpretation · 1996-07-18

Requirements for injury cases which result in treatment with prescription medication.

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 18, 1996 [Name Withheld] Dear [Name Withheld]: Thank you for your letter dated June 25, requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medication. As stated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, medical treatment includes "Use of PRESCRIPTION MEDICATIONS (except a single dose administered on first visit for minor injury or discomfort)." The case described in your letter resulted in the use of 1) a single dose of prescription medication employed as a local anesthetic and 2) a single dose of prescription medication used to treat/prevent infection. The treatment of this injury involved the use of two doses of prescription medication and is therefore considered medical treatment for OSHA recordkeeping purposes. For your information, OSHA is in the process of revising its injury and illness recordkeeping requirements. As can be seen on page 4059 of the enclosed Notice of Proposed Rulemaking, we are proposing to include the use of prescription drugs for diagnostic purposes within the definition of "first aid". 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 Division of Recordkeeping Requirements

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

Other letters on the same sections

Deciding a case of your own?

The free recordability check works through Part 1904 in the order the regulation sets out and quotes the provision behind every step.

Check a case — free

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.