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August 2, 1995

James F. Smith
Mountain Technical Center
10100 West Ute Avenue
Post Office Box 625005
Littleton, Colorado 80162-5005

Dear Mr. Smith:

Thank you for your letter dated June 15, requesting an interpretation regarding the classification of medical treatment for OSHA injury and illness recordkeeping purposes. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

For OSHA injury and illness recordkeeping purposes, use of hot or cold therapy or physical therapy on first visit to a health care professional should be considered first aid treatment (regardless of the number of modalities given). Physical therapies and heat/cold treatments are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel (see page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).

I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.

Sincerely,



Bob Whitmore
Chief
Division of Recordkeeping Requirements