Ezel / Labor Guidance / US
Back to Federal guidance

Rust-ring removal and former OSHA injury logs

Summary A requester asked whether treating a rust ring in an injured eye was recordable. Under OSHA’s former recordkeeping guidance, OSHA said removal of an embedded foreign body counted as medical treatment, while irrigation or a cotton swab for a nonembedded object could be first aid. OSHA marks the letter as archived and says it may no longer represent agency policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-06-16
Date issued
June 16, 1997
Status
Archived by the agency
OSHA labels this an archive document and says it may no longer represent agency policy; the page does not state a withdrawal or replacement.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping Medical Treatment
Source
View the official document

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

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OSHA labels this an archive document and says it may no longer represent agency policy; the page does not state a withdrawal or replacement.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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 16, 1997

William M. Bernhart, CIH
[Recipient address omitted]
Dear Mr. Bernhart:

Thank you for your letter dated June 2, 1997 asking if rust ring treatment of an eye injury is an OSHA recordable case.

As indicated on page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, any form of removal of foreign bodies embedded in the eye is considered medical treatment for recordkeeping purposes. This would include any technique to remove rust ring from the cornea. If the foreign body is not embedded, removal by means of irrigation or the use of a cotton swab are considered first aid. Any other means of removal (e.g. spud, etc.) must be considered medical treatment.

I hope you find this information helpful. If you have any further questions or comments, please contact my staff at Area Code (202) 219-6463.

Sincerely,

Bob Whitmore
Chief
Division of Recordkeeping Requirements

Related guidance

Permanently labeled locks for electrical lockout Opinion Letter · August 17, 2026 Helmet selection for lateral head-impact hazards Opinion Letter · August 17, 2026 Asbestos precautions when restoring drywall after flood damage Opinion Letter · May 7, 2026 Enforcement policy for recording and reporting COVID-19 cases Guidance · March 31, 2026

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace