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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 24, 1993

Mr. David E. Jones
Ogletree, Deakins, Nash, Smoak & Stewart
3800 One Atlantic Center
1201 West Peachtree Street, N.W.
Atlanta, Georgia 30309

Dear Mr. Jones:

Thank you for your letter dated March 8, requesting an interpretation on the proper recording of work related burns on the OSHA 200 Log. Whenever possible, I will refer to the Recordkeeping Guidelines for Occupational Injuries and Illnesses by citing page and Q&A numbers.

Non-pinhead work related second degree burns and all occupational third degree burns are recordable, regardless of the type of treatment given. Work related pin-head sized second degree burns and first degree burns are recordable if they involve loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment. As stated on page 42 of the Guidelines, the use of non-prescription medications is considered first aid for injury and illness recordkeeping purposes. Since you state that WaterJel is non-prescription, its use is considered to be first aid.

Regarding the use of antiseptics on second and subsequent visits to medical personnel, our current position and interpretation is as follows:

If the use of antiseptics on second or subsequent visits is the only criterion for making a case recordable, the case should not be recorded unless the antiseptic involved is one that requires a prescription in order to obtain it and it is used beyond a single dose. The recordability would then be based on our guidelines for the use of prescription medication as medical treatment.

I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.


Stephen A. Newell
Office of Statistics