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Historical prescription-drop injury recordkeeping

Summary A training company asked whether an eye injury treated with two single doses of prescription drops counted as medical treatment under then-current OSHA recordkeeping guidance. OSHA said it did because the exception applied to only a single prescription dose at the first visit. OSHA labels the letter archival.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-08-30-1
Date issued
August 30, 1991
Status
Archived by the agency
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Medical Treatment
Source
View the official document

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The current status of this document is unclear
This is an OSHA Archive Document, and may no longer represent OSHA Policy; OSHA presents it as historical content for research and review. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 30, 1991

Ms. Linda Balas
Environmental Management and Training Systems, Inc.
[Recipient address omitted]

Dear Linda:

Thank you for your letter of July 29 requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medications.

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

I hope this information will answer your questions about the recordkeeping requirements. If you have further questions please contact my staff at (202) 523-1463.

Sincerely,
Stephen A. Newell
Acting Director
Office of Statistics

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