Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

August 30, 1991

Ms. Linda Balas
Environmental Management and Training Systems, Inc.
4413 Copper Creek Lane
Toledo, Ohio 43615

Dear Linda:

Thank you for your letter of July 29 requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medications.

As stated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illness, medical treatment includes "Use of PRESCRIPTION MEDICATIONS (except a single dose administered on first visit for minor injury or discomfort)". The case you describe in your letter resulted in the use of 1) a single dose of prescription eye drops employed as a local anesthetic and 2) a single dose of prescription eye drops used to treat/prevent infection. The treatment of this injury clearly involved the use of two doses of prescription medication and is therefore considered medical treatment for OSHA recordkeeping purposes.

I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463.


Stephen A. Newell
Acting Director
Office of Statistics