OSHA Recordkeeping Handbook - Msabc.net

§1904.7strength? How is an employer to determine whethera non-prescription medication has been recommendedat prescription strength for purposes of section1904.7(b)(5)(i)(C)(ii)(A)?The prescription strength of such medications isdetermined by the measured quantity of the theraputicagent to be taken at one time, i.e., a singledose. The single dosages that are considered prescriptionstrength for four common over-the-counterdrugs are:Ibuprofen (such as Advil TM ;) - Greater than 467 mgDiphenhydramine (such as Benadryl TM ;) - Greaterthan 50 mgNaproxen Sodium (such as Aleve TM ;) - Greaterthan 220 mgKetoprofen (such as Orudus KT TM ;) - Greater than25mgTo determine the prescription-strength dosages forother drugs that are available in prescription and nonprescriptionformulations, the employer should contactOSHA, the United States Food and Drug Administration,their local pharmacist or their physician.Question 7-9 If an employee who sustains a workrelatedinjury requiring days away from work is terminatedfor drug use based on the results of a post-accidentdrug test, how is the case recorded? May theemployer stop the day count upon termination of theemployee for drug use under section 1904.7(b)(3) (vii)?Under section 1904.7(b)(3)(vii), the employer maystop counting days away from work if an employeewho is away from work because of an injury or illnessleaves the company for some reason unrelatedto the injury or illness, such as retirement or a plantclosing. However, when the employer conducts adrug test based on the occurrence of an accidentresulting in an injury at work and subsequently terminatesthe injured employee, the termination isrelated to the injury. Therefore, the employer mustestimate the number of days that the employeewould have been away from work due to the injuryand enter that number on the 300 Log.Question 7-10. Once an employer has recorded acase involving days away from work, restricted workor medical treatment and the employee has returnedto his regular work or has received the course of recommendedmedical treatment, is it permissible forthe employer to delete the Log entry based on aphysician’s recommendation, made during a year-endreview of the Log, that the days away from work,work restriction or medical treatment were not necessary?The employer must make an initial decision aboutthe need for days away from work, a work restriction,or medical treatment based on the information available,including any recommendation by a physicianor other licensed health care professional. Where theemployer receives contemporaneous recommendationsfrom two or more physicians or other licensedhealth care professionals about the need for daysaway, a work restriction, or medical treatment, theemployer may decide which recommendation is themost authoritative and record the case based on thatrecommendation. Once the days away from work orwork restriction have occurred or medical treatmenthas been given, however, the employer may notdelete the Log entry because of a physician’s recommendation,based on a year-end review of the Log,that the days away, restriction or treatment wereunnecessary.Question 7-10a. If a physician or other licensedhealth care professional recommends medical treatment,days away from work or restricted work activityas a result of a work-related injury or illness canthe employer decline to record the case based on acontemporaneous second provider’s opinion that therecommended medical treatment, days away fromwork or work restriction are unnecessary, if theemployer believes the second opinion is moreauthoritative?Yes. However, once medical treatment is provided fora work-related injury or illness, or days away fromwork or work restriction have occurred, the case isrecordable. If there are conflicting contemporaneousrecommendations regarding medical treatment, orthe need for days away from work or restricted workactivity, but the medical treatment is not actually providedand no days away from work or days of workrestriction have occurred, the employer may determinewhich recommendation is the most authoritativeand record on that basis. In the case of prescriptionmedications, OSHA considers that medical treatmentis provided once a prescription is issued.Question 7-11. Section 1904.7(b)(5)(ii) of the ruledefines first aid, in part, as “removing splinters orforeign material from areas other than the eye byirrigation, tweezers, cotton swabs or other simplemeans.” What are “other simple means” of removingsplinters that are considered first aid?68OSHA RECORDKEEPINGHANDBOOK