Standard Interpretations - Table of Contents
• Standard Number: 1904.4(a)

July 28, 2009

Ms. Linda Ballas
Linda Ballas & Associates
7129 Nightingale Drive
Holland, OH 43528

Dear Ms. Ballas:

Thank you for your June 8, 2009 letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. In an effort to provide you with prompt and accurate responses, we developed and continue to refine a set of Frequently Asked Questions (FAQ), in addition to maintaining a log of Letters of Interpretation (LOI) on the OSHA Recordkeeping website.

Scenario: An employee was assisting two other employees to put out a fire. All three employees were exposed to smoke, and were sent to a local hospital for precautionary reasons. Would the case be recordable if the ambulance driver administered oxygen to all three employees, not based on the symptoms presented by the injured, but merely based on local emergency responder ordinance, ambulance service protocol or general standing orders? The competent health care providers makes no decision, just follows the written rule, regardless of symptoms.

Response: The administration of oxygen is considered medical treatment for OSHA injury and illness recordkeeping purposes. If an employee is symptomatic of a work-related injury or illness (e.g., respiratory distress from smoke inhalation) and is administered oxygen, the case is recordable. The fact that the EMT administered the oxygen based on local emergency responder ordinance is not relevant.

Question 7-15. If an employee is exposed to chlorine or some other substance at work and oxygen is administered as a precautionary measure, is the case recordable?