OSHA Recordkeeping Handbook - Msabc.net

The first treatment is glue used to close a wound. The use of medical glue to close a wound is notfirst aid, and therefore must be considered medical treatment. First aid includes the use of the followingwound-covering devices: bandages, Band Aids©, gauze pads, butterfly bandages, or Steri-Strips©, 29 CFR 1904.7(b)(5)(ii)(D). Other wound-closing devices, such as sutures, staples, tapes,or glues are considered medical treatment. See 66 FR 5989 (January 19, 2001).The second treatment is the use of a prescription antibiotic for a puncture wound. Under the rule,the use of prescription medication to treat a wound is medical treatment. This follows even if themedication is an antibiotic or antiseptic administered following an injury to prevent a possibleinfection. In the preamble to the rule, OSHA specifically considered and rejected an exception forprescription antibiotics or antiseptics. See 66 FR 5986.Thank you for your interest in occupational safety and health. We hope you find this informationhelpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation lettersexplain these requirements and how they apply to particular circumstances, but they cannotcreate additional employer obligations. This letter constitutes OSHA’s interpretation of the requirementsdiscussed. Note that our enforcement guidance may be affected by changes to OSHA rules.In addition, from time to time we update our guidance in response to new information. To keepapprised of such developments, you can consult OSHA's website at http://www.osha.gov. If youhave any further questions, please contact my Division of Recordkeeping Requirements, at 202-693-1702.Sincerely,Keith Goddard, DirectorDirectorate of Evaluation and AnalysisLetter of interpretation related to sections 1904.5, 1904.5(a), 1904.5(b)(2), 1904.6, 1904.6(a), 1904.7 and 1904.31 –Evaluation of seven scenarios for work-relatedness and recordkeeping requirements.January 15, 2004Ms. Leann M. Johnson-Koch1200 Nineteenth Street, N.W.Washington, D.C. 20036-2412§1904.7Dear Ms. Johnson-Koch:Thank you for your E-mail to the Occupational Safety and Health Administration (OSHA) regardingthe Injury and Illness Recording and Reporting Requirements contained in 29 CFR Part 1904. Your letterwas forwarded to my office by Richard Fairfax, Director, Directorate of Enforcement Programs. TheDivision of Recordkeeping Requirements is responsible for the administration of the OSHA injury andillness recordkeeping system nationwide. Please excuse the delay in responding to your request.In your letter, you ask OSHA to clarify the following scenarios to ensure accurate and consistent guidanceto your members for purposes of OSHA Recordkeeping requirements. I will address your scenariosby first restating each one and then answering it.Scenario 1:• An employee reported to work at 7:00 a.m.• At 12:15 p.m. the employee reported that his toes on his left foot had started swelling and his foothad started hurting.• The employee wanted to go to a doctor for evaluation.• On the First Report of Injury, that the employee completed before he went to the doctor, the employeeindicated that the cause of the illness was “unknown (feet wet at cooling tower).”72OSHA RECORDKEEPINGHANDBOOK