Administering a post-exposure hepatitis B vaccine booster is considered medical treatment.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

August 4, 1999

Mitchell S. Y. Cohen, Esq.
Kaiser Foundation Health Plan, Inc.
One Kaiser Plaza, 21st Floor
Oakland, California 94612

Dear Mr. Cohen:

Topical skin adhesive used to close wounds is considered medical treatment.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 21, 1999

Robert Bower
Medcor Medical Administrator
American NTN Bearing Mfg. Corp
1500 Holmes Road
Elgin, Illinois 60123

Dear Mr. Bower:

Separate establishments require separate OSHA logs; No recent recordkeeping revisions.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 21, 1999

Dale J. Block
Director, Medical Services
Weirton Steel Corporation
400 Three Springs Drive
Weirton, West Virginia 26062-4989


Dear Dr. Block:

Recording injuries that occur at secondary facility of the same company.

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 https://www.osha.gov.

July 14, 1999

Scott Holt
Manager, Safety and Ecology
Knoll Pharmaceutical Company
30 North Jefferson Road
Whippany, NJ 07981

Dear Mr. Holt:

Thank you for your letter of April 1, 1999 requesting written confirmation of an interpretation you received verbally concerning which of two facilities of the same company should record an injury on its log. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Blue Book) whenever possible.

Fault plays no role in the OSHA recordkeeping system.

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 https://www.osha.gov.

June 24, 1999

Mr. Kurt Kreplin
Regional Human Resource Leader
International Paper
No. 1 IP Lane
Gurdon, Arkansas 71743

Dear Mr. Kreplin:

Recordability of injury/illness resulting solely from a physical defect.

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 https://www.osha.gov.

November 1, 1999

Dale H. Lyons, CSP
Manager of Safety and Health
Ethyl Petroleum Additives, Inc.
501 Monsanto Avenue
Sauget, Illinois 62201

Dear Mr. Lyons:

Thank you for your letter dated June 7, 1999 asking for a recordkeeping interpretation. I will respond by citing the regulations from 29 CFR Part 1904 and the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Recordkeeping Guidelines), by page and Q&A number(s), whenever possible.

Clarification of when injuries and illnesses are work-related and recordable.

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 https://www.osha.gov.

October 29, 1999

William K. Principe
Constangy, Brooks & Smith, LLC
Attorneys At Law
Suite 2400
230 Peachtree Street, NW
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Thank you for your letter of March 22, 1999 requesting an Interpretive Opinion Letter addressing recordability of the aggravation of a previous injury. I will cite the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Blue Book) whenever possible.

Recordkeeping: foreign workers working in U.S.; U.S. workers working abroad.

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 https://www.osha.gov.

December 7, 1999

Bruce Stagge
Mechanical Manager
Pinnacle Pigging Systems, Inc.
2720 East 1700 North
Layton, Utah 84040


Dear Mr. Stagge:

Injuries/illnesses from voluntary physical exams at work may be recordable.

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 https://www.osha.gov.

December 10, 1999

David B. Harold
Construction Safety Field Manager
Bechtel Savannah River, Inc.
Project Engineering and Construction Division
Aiken, South Carolina 29808

Dear Mr. Harold:

Thank you for your letter dated July 20, requesting that OSHA reevaluate its current position regarding the recording of injuries and illnesses which occur on the employer's premises when they result solely from participating in voluntary medical physical examination programs.

OSHA injury/illness recordabity must not impact medical treatment provided.

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 https://www.osha.gov.

December 10, 1999

Michael Patellos, MD MPH
Corporate Medical Director
Methodist Occupational Health Centers, Inc.
1812 N. Meridian Street
Indianapolis, Indiana 46202

Dear Dr. Patellos:

Thank you for your letter dated December 2, 1999, requesting clarification of an issue regarding the OSHA occupational injury and illness recordkeeping requirements.