July 31, 2000

Donald V. Lassiter, Ph.D.
Consultant, Environmental
& Occupational Health
Occupational Health Systems
2701 Sloane Street
Norman, OK 73032

Dear Mr. Lassiter:

Thank you for your letter of October 20, 1999 in which you ask for guidance concerning the OSHA recordkeeping requirements as they pertain to the use of a non-prescription preparation in response to a suspected exposure to hydrofluoric acid.

Scenario: "The issue concerns the use of a non-prescription formulation of calcium gluconate in standard KY jelly, which is used as a topical application to routinely treat suspected dermal exposures to hydrofluoric acid (HF). . . . [P]rolonged dermal contact with this particular acid can exacerbate the initial dermal burn, requiring medical treatment. The basis for the treatment procedure is to provide a preventive, or prophylactic, measure at the earliest possible moment following accidental dermal contact with this acid as a 'first aid' procedure. At the time of application, the identification of the liquid which has made contact with the skin may not be known and, in many cases, may be only water. However, because the employee may be working in a process in which dermal contact with HF is possible, the KY-calcium gluconate preparation is applied to prevent possible skin and soft tissue damage from occurring. In some instances, it is never known whether the 'wet agent' is water, HF or another chemical. This practice, in the absence of an actual injury, would seem to be preventive in nature-even when it is known that the agent on the skin is HF. It would also seem to be analogous to immediate use of an eyewash or shower to prevent bodily injury from continued exposure to a corrosive substance.

At the present time, this commodity is available from several commercial sources as a preventive HF burn preparation, without the requirement for a prescription. However, one company has contracted with a local pharmacy to produce a supply of this preparation as a non-prescription formulation. Individual containers of this preparation are made available to employees for immediate, preventative application, including possible repeated applications. Under these circumstances, a prescription is not required for use of the preparation by the employee, and in fact, the preparation is maintained as a 'first aid' item in the production area."

Answer: As indicated in Q&A B-6 on Page 30 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses, exposures to harmful substances, ". . . in and of themselves, are not recordable under Part 1904 of the regulations. Entries on the log, OSHA No. 200, and on the supplementary record, OSHA No. 101, should be made only when the exposure results in a recordable work injury or illness." As Q&As B-7 through B-9 on Page 30 of the Recordkeeping Guidelines indicate, if actions are taken "(1) To control the amount of employee exposure during a specific period of time or (2) to remove an employee from an area to prevent the development of adverse health effects" or care and medicine is given that is preventive in nature and the employee exhibits no evidence of injury or illness, than the case should not be recorded.

However, it is our understanding that there can be a latency period between the time of dermal exposure to hydrofluoric acid and the appearance of the resulting burn. Thus, there may be scenarios when the exposure to hydrofluoric acid results in a recordable burn to skin. As found on page 43 of the Recordkeeping Guidelines, treatment of first degree burns is generally considered to be first aid, and treatment of second and third degree burns is generally considered to be medical treatment. Thus, while exposure to HF -- even with the application of KY-calcium gluconate -- is not recordable, treatment of second or third degree burns resulting from exposure to HF is almost always recordable.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements at (202) 693-1702.

Sincerely,

Cheryle A. Greenaugh
Director
Directorate of Information Technology