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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 2, 1992

Donald L. Berling, M.D.
Plant Physician
Mead Paper
Post Office Box 2500
Chillicothe, Ohio 45601-2500

Dear Dr. Berling:

Thank you for your letter dated April 14 requesting an interpretation on recording eye injuries on the OSHA 200 Log. Please excuse the delay in our response.

We commend your practice of precautionary treatment of eye injuries and encourage a proactive approach to the prevention of minor injuries developing into more serious conditions. However, for the purpose of keeping the OSHA injury and illness recordkeeping system as simple and equitable as possible, we require that any work related injury requiring prescription medication (except a single dose administered on first visit for minor injury or discomfort) be recorded on the OSHA 200 Log. Thus, any prescription medicine actually provided regardless of the purpose for which it is given, is considered medical treatment (please see page 44 Q & A F-5 in the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses). Following the supplemental instructions as presented in the Guidelines leads to consistent, useful records nationwide.

If you have any further questions or comments, please contact my staff at (202) 523-1463.


Acting Director
Office of Statistics


April 14, 1992

Steve Newell
Acting Director of Statistics
Department of Labor
200 Constitution Ave. N.W.
Room 3507
Washington D.C. 20210

Dear Mr. Newell,

Oftentimes treatment with eye preparations, such as Erythromycin or topical Sulfa preparations are used in a prophylactic manner, even though the injury itself may be minimal. Application of topical antibiotics is fairly standard treatment for even the most trivial eye injury, like minor abrasions or conjunctivitis of various types. Certainly the opposite approach, i.e., not applying antibiotic preparations to prevent the injury from being recordable, could prove to be most costly in terms of producing an adverse result.

Therefore, we ask that every eye we treat with two or more applications of a prescription ointment should not automatically be OSHA recordable. We would carefully examine each incident and make the determination according to the history, the severity of the injury and whether it is truly treatment or used as a preventive measure.

Thank you for your consideration of this matter.

Donald L. Berling, M.D.
Plant Physician

James Segelhorst
Plant Safety

Shirley Pigott, R.N.
Nurse Supervisor