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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 23, 1995

F. R. Smith
Department Manager
Safety, Security and Fire Protection
U.S. Steel Clariton Works
400 State Street
Clariton, Pennsylvania 15025-1855

Dear Mr. Smith:

Thank you for your letter dated May 4, requesting an interpretation regarding the determination of medical treatment for OSHA injury and illness recordkeeping purposes. I will address your questions in the order they were presented.

Issue Number 1: As can be seen in the attached August 30, 1991 letter of interpretation to Linda Ballas, treatment involving a single dose of prescription medicine employed as a local anesthetic and a single dose of prescription medication used to treat or prevent infection is regarded as medical treatment involving multiple doses of prescription medication. At the present time OSHA is in the process of revising the entire injury and illness recordkeeping regulation (29 CFR 1904), forms and interpretive materials. As part of that process, the definitions of first aid and medical treatment are being reviewed. OSHA is seriously considering the inclusion of prescription drugs used solely for diagnostic purposes in its definition of first aid. When the Notice of Proposed Rulemaking (NPRM) is published in the Federal Register, we certainly welcome your input on this and any other portion of the proposed revision.

Issue Number 2: As explained on page 42, section F of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, records must be maintained for work injuries "...other than minor injuries requiring only first aid treatment, and which do not involve medical treatment..." and F-5 on page 44 "...the requirement for recording medical treatment injuries focuses on whether the injury was serious enough that medical treatment was actually provided, or should have been provided." The focus is on the fact that qualified hospital staff provided medical treatment and therefore makes the work related cases in question recordable (See the attached July 23, 1991 memorandum to James Stanley). Once a prescription is issued, it is considered medical treatment. Whether the prescription is filled or taken does not alter this determination.

In regards to cases involving restricted work activity, if the plant physician examines an employee the day after the injury or illness and determines that the employee can work at full capacity, the case should not be considered a recordable involving restricted work activity and no days of restricted work need to be counted. Please remember that a case where the employee is restricted on the day of the injury or illness only, must be recorded as a case without lost workdays (column 6 or 13) regardless of whether it is recordable for any other reason. (See Q&A C-2, page 52 of the Recordkeeping Guidelines).

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


Bob Whitmore
Division of Recordkeeping Requirements