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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

May 17, 1993

Mr. Elmer J. Hlavaty
Miles Inc.
Mobay Road
Pittsburgh, Pennsylvania 15205-9741

Dear Mr. Hlavaty:

Thank you for your facsimile dated April 23, requesting confirmation of several interpretations on OSHA recordkeeping requirements you received in your telephone conversation with Bob Whitmore of my staff. Your understandings as contained in the fax are correct. In addition I will address each topic in more detail and will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses whenever possible.

Fractures: As found on page 42 of the guidelines, an injury is not considered minor if it results in damage to the physical structure of a nonsuperficial nature (e.g. fractures). Any work related injury that is not minor must be recorded.

Second degree Any work related second degree burn, other than burns: pin-head sized, must be recorded regardless of treatment provided.

Eye injuries: Any form of removal of foreign bodies embedded in the eye is considered medical treatment for recordkeeping purposes, as is found on page 43 of the Guidelines. 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. Any other means of removal (e.g. spud, etc.) must be considered medical treatment.

Hot or cold As found on page 43 of the Guidelines, application treatments: of heat or cold therapy on the first visit to medical personnel is considered first aid. Heat or cold therapy on a second or subsequent visit to medical personnel (or self-administered treatment made available to employees by their employer on premises) is considered medical treatment. Please be aware that this means only one application of heat or cold therapy is necessary to meet the medical treatment requirements.

Preexisting An employee's physical defect or preexisting condition: physical condition does not affect the determination of recordability (Q&A B-14, page 31). The general rule is that all injuries and illnesses which result from events or exposures occurring on the employer's premises are presumed to be work related (Q&A C-7, page 34).

I hope you find this information helpful. I have also enclosed two recent court decisions for your information. If you have any further questions or comments, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell
Office of Statistics