Answer Library / Recordkeeping OSHA letter · 2018-09-13

Is an EpiPen injection recordable under OSHA?

Quick answer

Yes. OSHA says using a prescription EpiPen to treat a work-related event like a bee sting is medical treatment beyond first aid and must be recorded on the OSHA 300 log (29 CFR 1904.7(a)). It does not matter that the prescription was personal, unrelated to the job, or used before symptoms appeared.

An oil and gas trade association asked OSHA about an outdoor lease operator with a known bee sting allergy who carries a personal EpiPen. After being stung at work, the employee injected himself as a precaution — before any allergic symptoms appeared. The association asked whether this precautionary use of a personal, non-work-related prescription is recordable.

OSHA answered yes. Under 29 CFR 1904.5(a), 'an injury or illness must be considered work-related if an event or exposure in the work environment either caused or contributed to the resulting condition.' The bee sting was a work-related event that significantly aggravated the employee's pre-existing allergic condition. And because 'the issuance of prescription medication is considered medical treatment beyond first aid,' the case must be recorded on the OSHA Form 300 (1904.7(a)).

The association also asked whether the answer changes if the employee waits until symptoms appear before using the EpiPen. OSHA said no — the case is recordable either way. Work contributed to the injury through the bee sting, and medical treatment beyond first aid (the prescription EpiPen injection) was administered for that work-related injury, satisfying the criteria in section 1904.7. Whether symptoms had ensued makes no difference.

29 CFR 1904.5(a)29 CFR 1904.7(a)29 CFR 1904.7
Source: OSHA Standard Interpretation letter, 2018-09-13 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

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