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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 18, 1996

[Name Withheld]

Dear [Name Withheld]:

Thank you for your letter dated June 25, requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medication.

As stated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, medical treatment includes "Use of PRESCRIPTION MEDICATIONS (except a single dose administered on first visit for minor injury or discomfort)." The case described in your letter resulted in the use of 1) a single dose of prescription medication employed as a local anesthetic and 2) a single dose of prescription medication used to treat/prevent infection. The treatment of this injury involved the use of two doses of prescription medication and is therefore considered medical treatment for OSHA recordkeeping purposes.

For your information, OSHA is in the process of revising its injury and illness recordkeeping requirements. As can be seen on page 4059 of the enclosed Notice of Proposed Rulemaking, we are proposing to include the use of prescription drugs for diagnostic purposes within the definition of "first aid".

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


Bob Whitmore
Division of Recordkeeping Requirements