When is Post-Exposure Prophylaxis OSHA Recordable?

Employees may be exposed to patients with pertussis, neisiria meningitis, scabies/lice, or other potentially infectious organisms, and it is important to provide medication to prevent these employees from acquiring any disease/organism from the infected patient. In the past, I have always considered prescription medication, even if given once, OSHA recordable. In talking to other employee health nurses, they have also verbalized the same consideration.

I have been discussing this with some of my OSHA counterparts and wrote a letter to OSHA for a letter of interpretation. Valerie Struve, a representative from the National OSHA office, called me to clarify when treatment is OSHA recordable. I incorrectly had made over 50 individual exposure cases OSHA recordable because we provided prophylaxis for them as a result of an exposure to a severe case of Norwegian scabies. Valerie was very helpful and clearly explained when prophylactic treatment is considered OSHA recordable and when it is not.

She directed me to the chart below to determine if an exposure could be recordable, and she explained for it to be recordable, there needs to be an injury. It could be a tick bite, human bite, or other type of injury to an individual. If there is an injury and prophylaxis was given, then it would be OSHA recordable. That is because, if not for the injury, treatment would not need to be given. If there never was an injury, but to prevent an injury/illness prophylaxis was given, then it would not be OSHA recordable.

(Please note there are additional criteria for needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, medical removal cases, and musculoskeletal disorder cases.)

I hope you find this helpful. If you have any additional questions, Valerie welcomes your call. Her number is 202-693-1882.

Bobbi Jo Hurst, MBA, BSN, RN, COHN-S, SGE
AOHP Association Community Liaison