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TSAOHN Member responses:
1.
This is my opinion: the use of a Morgan
Lens is medical treatment based on the following:
In making its decisions about the items to be included on the list of
first aid treatments, OSHA relied on its experience with the former rule,
the advice of the Agency's occupational medicine and occupational nursing
staff, and a thorough review of the record comments. In general, first aid
treatment can be distinguished from medical treatment as follows:
Documentation
- First aid is usually administered
after the injury or illness occurs and at the location (e.g., workplace)
where the injury or illness occurred.
- First aid generally consists of
one-time or short-term treatment.
- First aid treatments are usually
simple and require little or no technology.
- First aid can be administered by
people with little training (beyond first aid training) and even by the
injured or ill person.
- First aid is usually administered to
keep the condition from worsening, while the injured or ill person is
awaiting medical treatment.
- In the final rule, OSHA has included
as item J "Removing foreign bodies from the eye using only irrigation or
a cotton swab." OSHA believes that it is often difficult for the health
care professional to determine if the object is embedded or adhered to
the eye, and has not included this suggested language in the final rule.
In all probability, if the object is embedded or adhered, it will not be
removed simply with irrigation or a cotton swab, and the case will be
recorded because it will require additional treatment.
OSHA believes that it is appropriate to
exclude those cases from the Log that involve a foreign body in the eye of
a worker that can be removed from the eye merely by rinsing it with water
(irrigation) or touching it with a cotton swab. These cases represent
minor injuries that do not rise to the level requiring recording. More
significant eye injuries will be captured by the records because they
involve medical treatment, result in work restrictions, or cause days away
from work
Addendum:
OSHA’s new definition of first aid
includes:
Documentation
- Using a nonprescription medication at
nonprescription strength;
- Cleaning, flushing, or soaking wounds
on the surface of the skin;
- Using hot or cold therapy;
- Using any temporary immobilization
devices while transporting a victim;
- Draining fluid from a blister;
- Removing foreign bodies from the eye
using only irrigation or a cotton swab;
- Using finger guards;
- Use of a massage (though physical and
chiropractic therapy are defined as medical treatment); and
- Drinking fluids for relief of heat
stress.
Multiple applications of first aid do
not represent medical treatment, according to OSHA. It is the nature of
the treatment, not how many times it is applied, that defines whether it
is first aid or medical treatment, according to the agency.
Submitted by CC
2.
Initially, I would not know of an instance where a Morgan Lens would be
used outside of a chemical or physical injury to the eye, predisposing the
event to an OSHA recordable status. Normal rinsing is very important and
if simple rinsing (non-recordable first aid) is not effective, by nature
of ‘bumping up the care level’ to utilizing a Morgan Lens set-up would, in
my opinion, make the activity OSHA recordable. Additionally, when
utilizing a Morgan set-up, my protocol calls for a topical anesthetic,
thus also making the activity recordable. Hope this helps. We hear it all
the time, ‘It is better to err on recording than not’. Submitted by CB
3.
Although ringers is a Rx for IV use – using it strictly to flush would
still be a first aid case unless there was an injury to eye that required
Rx medication to treat the injury (Rx eye drops – antibiotic or numbing).
Submitted by KM
4. No it is first aid.
Submitted by DS
5. It's First Aid. The only reason the NaCl is Rx is because the packaging of
the IV bottle is routinely used for IV solutions-- not because of the
saline. - you could use the Morgan lens with a flush bottle of saline or
water if you had to. Or you could hold the eye open w/your fingers. The
Morgan's lens is just an easier tool for flushing.
The use of the lens is still first aid and not medical because still
remains a topical application of NaCl flushing and not intravenous
infusion. (if the object was imbedded, it would be different. It's just
simple flushing.) Submitted by MG
6.
http://www.morganlens.com/faq.html
If you go to the website above, you will find that the manufacturer
recommends LR, but, I was taught to use NS, initially and it works fine
and it is not an Rx item, keeping this a first aid issue and
non-recordable. The pH of LR is closer to that of the eye, but NS is very
close, as well. The use of the Morgan Lens does not have to be ordered by
a physician. Submitted by RW
7. I have attached the
OSHA General Recoding Criteria 1904.7 which states
first aid includes:
- Removing foreign bodies from the eye using only irrigation or a cotton
swab
So, if the foreign body is not imbedded and not chemical in nature,
irrigating the eye is considered first aid.
As far as I know, this has not changed.
Submitted by AM
8. I would answer "No- Not OSHA recordable" for merely using the Morgan Lens
to flush and/or inspect the eye. I would not consider this treatment
beyond first aid unless a finding was identified such as embedded object,
corneal abrasion, corneal damage from chemical contact, etc. The fact that
a prescription may be needed to use the Morgan Lens, such as to order the
IV irrigation solution, does not make it OSHA recordable in and of itself.
There are other examples where prescriptions are used under the "first
aid" category, e.g. oxygen given during an emergency response requires a
standing order/prescription but it is not considered treatment beyond
first aid unless it is being used to treat a condition, Td requires a
prescription but it is not considered OSHA when administered as a booster
following a minor laceration that otherwise does not require treatment
beyond first aid, an x-ray requires a prescription but is not OSHA
recordable if the x-ray is negative, a blood draw requires a
prescription/standing order but it is not OSHA recordable by itself; only
if adverse findings are identified, i.e. elevated blood lead level.
This is explained in the OSHA regulation at:
- For the purposes of Part 1904, medical treatment does not
include:1904.7(b)(5)(i)(A)
- Visits to a physician or other licensed health care professional solely
for observation or counseling;
- 1904.7(b)(5)(i)(B)
- The conduct of diagnostic procedures, such as x-rays and blood tests,
including the administration of prescription medications used solely for
diagnostic purposes (e.g., eye drops to dilate pupils) Submitted
by AHM
9. My response would be: There is not verbiage on what solution you use for
eye flush for recordkeeping purpose. If you are using the solution to
inject it is recordable. The language is for whether it's imbedded or not
and I would not record it. You are using the rinse in a
prophylactic/preventive measure? The question to ask yourself is: IS there
an injury that is classified as recordable that warrants the flush???
Submitted by LR
10. It is not recordable. Morgan Lens treatment is not medical
treatment. The use of the IV fluids is for a flush purpose and is not
being administered by a IV drip.
Submitted by PW
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