A part of any proficient safety program is the reporting process. Without reporting there can be no trend analysis or measure of success for implemented practices. The Occupational Safety and Health Act is no different. Recognizing the need for standardized reporting, 29 CFR 1904.7 outlines the general reporting criteria. The final rule clarifies the reporting criteria for all incidents of injury and illness requiring treatment beyond first aid. To simplify the definition of first aid paragraph (b)(5)(ii) (A thru N) list 14 treatments defined as first aid. 1904.7(b)(5)(ii)(B) list administering tetanus immunizations as first aid. However, it lists other immunizations and vaccines as medical treatment. This standard as simply as it is written
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How could one immunization be an acceptable prophylactic following an injury while other immunizations and vaccines would not be? Given there are a few requests for interpretations, it may not be clear to others as well. After further reading of the record of rulemaking, the intent for the inclusion of tetanus immunizations becomes apparent.
In the clarification OSHA contends “immunizations and inoculations that are provided for public health or other purposes, where there is no work-related injury or illness, are not first aid or medical treatment, and do not by themselves make the case recordable” (Record Keeping, n.d.). Therefore, in this case, the tetanus immunization is given based upon the individual’s last immunization and not necessarily the injury.
On 23 June 2003 Ms. Donna Majewski of the Great Lakes Chemical Corporation requested interpretation of the standard based on a the administration of an anti-viral treatment given to an employee that was bitten by a macaque monkey, who are known to carry Herpes Virus 1. In this scenario the treatment was given prior to testing of the monkey. After the monkey was tested the treatment was deemed unnecessary. OSHA interpreted the standard to read because the treatment was administered for a work related injury it met the standard for general reporting criteria for immunizations, except tetanus. Here the doctor had little choice as delaying the treatment could have
How could one immunization be an acceptable prophylactic following an injury while other immunizations and vaccines would not be? Given there are a few requests for interpretations, it may not be clear to others as well. After further reading of the record of rulemaking, the intent for the inclusion of tetanus immunizations becomes apparent.
In the clarification OSHA contends “immunizations and inoculations that are provided for public health or other purposes, where there is no work-related injury or illness, are not first aid or medical treatment, and do not by themselves make the case recordable” (Record Keeping, n.d.). Therefore, in this case, the tetanus immunization is given based upon the individual’s last immunization and not necessarily the injury.
On 23 June 2003 Ms. Donna Majewski of the Great Lakes Chemical Corporation requested interpretation of the standard based on a the administration of an anti-viral treatment given to an employee that was bitten by a macaque monkey, who are known to carry Herpes Virus 1. In this scenario the treatment was given prior to testing of the monkey. After the monkey was tested the treatment was deemed unnecessary. OSHA interpreted the standard to read because the treatment was administered for a work related injury it met the standard for general reporting criteria for immunizations, except tetanus. Here the doctor had little choice as delaying the treatment could have