- Standard Number:
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 https://www.osha.gov.
February 25, 1992
Mr. R. L. Kuhn Director,
Safety, Health & Environmental Affairs
McDonnell Douglas Corporation
Post Office Box 516
Saint Louis, Missouri 63166-0516
Dear Mr. Kuhn:
Thank you for your letter of January 24, requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with butterfly adhesive dressings or Steri Strips(1).
As stated on page 43 of the enclosed Recordkeeping Guidelines for Occupational Injuries and Illness, medical treatment includes the "Application of sutures (stitches)" as well as the "Application of butterfly adhesive dressing(s) or Steri Strip (s) in lieu of sutures" (emphasis added.) The emphasized phrase is not a qualifying statement referring to the reason for use, but rather a statement of fact. Butterflies and Steri Strips are used in lieu of sutures. As shown in the enclosed material from the BLS Report 412-3, page 2, the recording of a work related injury that involves the use of "butterfly sutures" was established well before the issuance of the 1986 recordkeeping guidelines. Conversely, first aid treatment has always included the "Application of bandage(s) during any visit to medical personnel".
The concept that underlies the medical treatment vs. first aid distinction made between these types of treatments centers around the basic difference between wound closures and wound coverings. Sutures (stitches), Steri Strips, staples, butterfly dressings, etc. are all classified as wound closures, while bandages (Band-Aids(2), gauze pads, etc.) are wound coverings. Simply stated, any use of a wound closure is considered medical treatment for OSHA recordkeeping purposes, while the use of a wound covering is deemed to be first aid treatment.
________ Footnote(1) Steri Strip is a registered trademark of 3M Corporation.
Footnote(2) Band-Aids is a registered trademark of Johnson & Johnson Corporation.
Any work related injury that results in medical treatment must be recorded on the OSHA 200 Log. The fact that such treatment is not administered by a physician is immaterial for recordkeeping purposes. Page 42 of the guidelines states that physicians routinely treat minor injuries with first aid. Conversely, medical treatment can be provided to employees by lay personnel.
The fact that such treatment is prophylactic or preventive in nature is also not a determining factor. Almost any treatment can be stated in preventive terms. For example, treatment with antibiotics is used to prevent infection. Sutures are often used to align the edges of small wounds and to promote healing. The OSHA recordkeeping system relies simply on the treatment that was provided, or in the absence of such treatment, clearly should have been provided. There is no emphasis on the intention or purpose of the treatment.
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
Office of Statistics