- 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.
September 24, 1992
Ms. Linda Ballas
4413 Copper Creek Lane
Toledo, Ohio 43615
Thank you for your letter dated July 17 requesting an interpretation for recording eye injury cases on the OSHA Log 200. Please excuse our delay in responding.
Any form of removal of foreign bodies embedded in the eye is considered medical treatment for recordkeeping purposes, as is stated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses. This would include any technique to remove rust ring from the cornea. If the foreign body is not embedded, removal by means of irrigation or the use of a cotton swab are considered first aid. It came to our attention after the writing of the Guidelines that the use of a cotton swab is a means of removal as simple and effective as the use of irrigation. Any other means of removal must be considered medical treatment, e.g spuds, etc.
Is removal of a foreign body from the eyelid >recordable if other than flushing is used? (i.e. moist cotton swab)
Foreign bodies in the eyelid should be evaluated using the criteria associated with removal of "foreign bodies from wound" rather than from the eye. If the procedure for removal is complicated because of depth of embedment, size, or location, than it should be considered medical treatment. If the procedure is uncomplicated and done by simple means (e.g. irrigation, cotton swab, etc.) it should be considered first aid.
Is removal of a foreign body from the eye recordable if other than flushing is used? (i.e. moist cotton swab)
If removal of a non-embedded foreign body from the eye is done by means other than irrigation or the use of a cotton swab, the case must be recorded.
What if the medical personnel believe the foreign body does not appear to be embedded and does not believe irrigation is required, and instead uses a moist cotton swab on the eye or eyelid? Is this medical treatment or first aid?
If removal of a non-embedded foreign body from the eye is done by the means of irrigation or the use of a cotton swab, it should be considered first aid.
I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 523-1463.
Stephen A. Newell
Office of Statistics