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 http://www.osha.gov.
March 16, 1995
Mr. Ronnie Powell
Union Carbide Corporation
Houston, Texas 77058
Dear Mr. Powell:
Thank you for your letter dated February 27, requesting interpretations on two OSHA injury and illness recordkeeping issues.
Issue 1: As stated in your letter, tetanus or tetanus booster shots are not considered medical treatment for OSHA injury and illness recordkeeping purposes. Furthermore, a single dose of prescription medication on first visit to medical personnel for a minor injury or discomfort is considered first aid. If the diphtheria portion of the tetanus/diphtheria shot is administered as a single dose, the shot should be considered first aid.
Issue 2: When evaluating hernias for work relationship, all types of hernias should be evaluated using the same criteria. If the hernia arises on the employer's premises, work relationship is presumed. If an event or exposure within the work environment either caused or contributed to the condition, or aggravated a preexisting condition, it is considered work related for OSHA injury and illness recordkeeping purposes.
I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.
Bob Whitmore Chief
Division of Recordkeeping Requirements