OSHA Interpretation Letter Helps to Clarify Medical Treatment Beyond First Aid

OSHA requires most employers with more than 10 employees to keep records of certain work related injuries and illnesses, including those that result in the need for medical treatment beyond first aid. Starting in 2017, some employers will be required to submit this information to OSHA electronically. As employers prepare to comply with new rule, substantial confusion still exists in some circles about proper classification of recordable incidents — something which is not always obvious. However, a new letter of interpretation recently published by OSHA may help clarify some common misunderstandings about medical advice, and how it determines what is considered medical treatment beyond first aid, and therefore a recordable incident per OSHA’s definition.

In the letter, OSHA responds to a submitted question about a scenario in which a worker experiences wrist pain after working on a computer and begins to wear a brace with no prompting from a medical professional. The employee then visits a physician, who advises the employee to continue to wear the brace. The question is then asked, does this constitute medical treatment beyond first aid for recordkeeping purposes?

As OSHA states in the letter, it generally “does not consider self-treatment or self-medication by the employee to constitute medical treatment beyond first aid.” However, in this case, because a physician “seconded” the employee’s self-treatment and recommended the brace, it does now qualify as medical treatment beyond first aid. Thus, it is an injury or illness that meets general recording criteria and is therefore recordable. This incident would need to be entered on an OSHA 300 log, and would need to be electronically submitted once the new electronic reporting rule goes into effect.

This clarification drives home what the rule already states. Namely, that you must record “a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.”

It’s always a good idea to get and stay familiar with which activities OSHA defines as “first aid.” They can sometimes be surprising, and can involve materials or activities beyond what’s available through a typical first aid kit. For example, here is a sampling of what OSHA considers non-recordable first aid activities:

  • Receiving tetanus shots
  • Using eye patches
  • Wearing non-rigid back belts
  • Receiving massages

Further, it is important when keeping on top of recordable injuries and illnesses to remember that certain specific injuries and illnesses have special rules and regulations. Some of these include:

  • Needlesticks
  • Medical removal
  • Hearing loss
  • Contraction of tuberculosis

For more information on OSHA’s rulings and clarifications surrounding medical treatment beyond first aid, you can visit OSHA’s dedicated webpage here.

For a synopsis of upcoming changes to recordkeeping requirements, check out this article on the VelocityEHS blog.

If you’re feeling like you might need some additional help, keep in mind that an electronic solution can be a powerful tool for helping to meet the requirements and stay on top of the timelines of the Recordkeeping Rule. A cloud-based EHS management software solution can provide a central hub for all of the data that employers are required to maintain, and can give you the ability to easily record, track, and report on all types of incidents. For more information on how an electronic system can help reduce your burden, while providing increased visibility into your organization’s overall injury, illness and near-miss incidents so you can prevent future incidents, visit the Incident Management page on our VelocityEHS website.

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