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Prescription medication and older injury-log medical treatment

Summary Under the older recordkeeping guidelines, OSHA viewed one dose of local anesthetic and one dose to treat or prevent infection as two prescription doses, making the case medical treatment rather than the single-dose first-aid exception. OSHA archives this letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-07-18-0
Date issued
July 18, 1996
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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