# Letters of Interpretation
1 - 1904.7 - Red Light Therapy Wraps
2 - 1904.7 - Is the use of paraffin wax as a form of topical heat application considered medical treatment beyond first aid for OSHA recordkeeping purposes
3 - 1904.7 - Enforcement Guidance Under OSHA's Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching Are Used to Treat Musculoskeletal Injuries and Illnesses
4 - 1904.7 - Determining the recordability of an illness when an employee uses a rescue inhaler following an exposure in the work place.
5 - 1904.7(b)(5)(ii) - Use of Zipstitich and Clozex to close a wound is medical treatment beyond first-aid.
6 - 1904.7(b)(5)(ii) - Clarification of soft tissue massage
7 - 1904.7(b)(3) - Clarification on how to count calendar days resulting in days away from work
8 - 1904.7(b)(3) - Foreign-Flag Vessels.
9 - 1904.7(b)(5)(ii) - Clarification on the use of cold therapy.
10 - 1904.7(b)(5)(ii)(F) - The use of braces with rigid stays.
11 - 1904.7 - Prescription medications, such as an Epi-Pen considered medical treatment beyond first-aid.
12 - 1904.7(b)(5)(ii) - Clarification on the use of a cold therapy only setting on a therapeutic device is first-aid
13 - 1904.7(b)(5) - Clarification on the use of a cold compression device is considered medical treatment.
14 - 1904.7(b)(7) - Clarification on the use of a rigid boot as a precautionary measure
15 - 1904.7(b)(7) - Determining if the employees experienced an injury or illness due to an exposure.
16 - 1904.7(b)(4) - Determining if a work-related injury or illness resulted in restricted work activity/Job Transfer
17 - 1904.7(b)(5) - Clarification on the use of preventative exercise as an intervention strategy
18 - 1904.7(b)(5)(ii)(F) - Recordkeeping Regulation contained in 29 CFR Part 1904
19 - 1904.7 - Determining whether daily stretches are considered medical treatment or fist-aid.
20 - 1904.7 - Clarification on the recording of injuries involving broken or chipped teeth
21 - 1904.7 - Determining whether an injury or illness is work-related and recordable
22 - 1904.7 - Use of kinesiology tape is not considered medical treatment beyond first aid.
23 - 1904.7 - Clarification regarding the applicability of the recording criteria involving restricted work.
24 - 1904.7 - Prescription medications, including preventive antibiotics, are considered medical treatment and are recordable.
25 - 1904.7 - Clarification of a pre-existing injury or illness and recordable events
26 - 1904.7(b) - Determine Whether the Employer is Required to Record a Work-related Injury Sustained by an Employee which was Treated by a Reduction Procedure Performed on Her Dislocated Ring Finger
27 - 1904.7 - Clarification on whether an exercise regime is first aid or medical treatment
28 - 1904.7 - Clarification on recordability when trigger point injections are used for medical treatment and for diagnostic procedures
29 - 1904.7 - Recording an absence as days away when PLHCP recommends the employee return to work.
30 - 1904.7 - Clarification on hot therapy as first aid.
31 - 1904.7 - Recording days away and/or restricted work activity when employee is able to work part of a shift.
32 - 1904.7 - Therapeutic exercise is considered medical treatment for recordkeeping purposes.
33 - 1904.7 - Clarification on pre-existing conditions and recordable incidents
34 - 1904.7 - Whether manual joint manipulation is considered first aid or medical treatment for recordkeeping purposes
35 - 1904.7(b)(5)(ii)(A) - Clarification on prescription medications and recordkeeping requirements
36 - 1904.7 - Health impacts from shared office equipment.
37 - 1904.7 - Clarification of the term self-inflicted as used in the Recordkeeping standard
38 - 1904.7 - Counting restricted days for a part-time employee
39 - 1904.7 - Clarification of several recordkeeping scenarios regarding days away from work, restricted work activity, and work-relatedness.
40 - 1904.7 - Clarification of the term "contemporaneous" as used in recordkeeping FAQ 7-10a.
41 - 1904.7 - Whether damage to employee dentures is a recordable injury.
42 - 1904.7 - Clarification of several recordkeeping scenarios regarding the use of prescription medication in treating a work-related case.
43 - 1904.7 - Recording an injury when physician recommends restriction but no restricted work is available.
44 - 1904.7(b)(5)(ii) - Determining whether Active Release Techniques (ART) constitutes first-aid or medical treatment.
45 - 1904.7 - No Restricted Work Available
46 - 1904.7 - Recordkeeping requirements when an employer receives two or more differing medical recommendations for an injury/illness.
47 - 1904.7 - Restrictions from restricted work activities.
48 - 1904.7 - Determination of a case as days away or restricted work; case must be recorded in manner reflecting what actually occurs.
49 - 1904.7(b) - Once medical treatment beyond first aid has occurred for injury or illness the case must be recorded.
50 - 1904.7 - All prescription medications, including preventive antibiotics, should be considered medical treatment and are recordable.
51 - 1904.7(b)(5)(ii) - Use of glue to close a wound is medical treatment; prescription antibiotics/antiseptics for preventive treatment of a wound is medical treatment.
52 - 1904.7 - Evaluation of seven scenarios for work-relatedness and recordkeeping requirements.
53 - 1904.7(b)(5)(ii)(B) - Immunizations or inoculations (except tetanus) are recordable when given in response to a workplace injury or illness.
54 - 1904.7 - Results of an MRI do not negate the recordability of a physician's recommendation.
55 - 1904.7(b)(5)(ii)(D) - Use of liquid bandages on wounds is considered first aid.
56 - 1904.7(b)(5)(ii)(A) - Recording of cases in which a health care professional issues a prescription, whether that prescription is filled or not.
# Federal Register
1 - 1904.7 - 90:34887-34897 - McNally Tunneling Corp./ASI Marine Southerly Tunnel and Consolidation Project; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments
2 - 1904.7 - 88:80764-80771 - NASA Neutral Buoyancy Laboratory Operations Contract; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
3 - 1904.7 - 88:15090-15100 - Traylor-Shea Joint Venture: Grant of Permanent Variance - PDF
4 - 1904.7 - 90:34902-34911 - CBNA/Halmar Joint Venture; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments
5 - 1904.7 - 90:28257-28263 - Occupational Injury and Illness Recording and Reporting Requirements; Withdrawal
6 - 1904.7 - 89:70698-71073 - Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings; Proposed Rule - PDF
7 - 1904.7 - 89:21274-21284 - Ballard Marine Construction Lower Olentangy Tunnel Project; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
8 - 1904.7 - 88:80771-80777 - KBR Wyle Services, LLC; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
9 - 1904.7 - 88:51862-51872 - Ballard Marine Construction Bay Park Conveyance Tunnel Project; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
10 - 1904.7 - 88:26600-26610 - Traylor Bros., Inc.; Application for Modification of Permanent Variance and Interim Order; Grant of Interim Order - PDF
11 - 1904.7 - 88:15080-15090 - McNally/Kiewit Joint Venture: Grant of Permanent Variance - PDF
12 - 1904.7 - 87:58379-58389 - McNally/Kiewit Shoreline Storage Tunnel Joint Venture; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
13 - 1904.7 - 87:54536-54547 - Traylor Bros. Inc.; Application for Modification of Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
14 - 1904.7 - 87:18528-18558 - Improve Tracking of Workplace Injuries and Illnesses; Proposed Rule - PDF
15 - 1904.7 - 86:59309-59326 - Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings - PDF
16 - 1904.7, 1904.7(a) - 86:59309-59326 - Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings - PDF
17 - 1904.7 - 86:32376-32628 - Occupational Exposure to COVID-19; Emergency Temporary Standard; Interim Final Rule
18 - 1904.7 - 86:5253-5263 - Ballard Marine Construction; Application for Permanent Variance and Interim Order; Grant of Interim Order - PDF
19 - 1904.7 - 85:27767-27775 - Salini-Impregilo/Healy Joint Venture: Grant of Permanent Variance - PDF
20 - 1904.7 - 84:44932-44942 - Salini-Impregilo/Healy Joint Venture; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
21 - 1904.7 - 84:21822-21832 - Jardon and Howard Technologies, Incorporated; Grant of a Permanent Variance - PDF
22 - 1904.7 - 84:380-406 - Tracking of Workplace Injuries and Illnesses - PDF
23 - 1904.7 - 83:36494-36507 - Tracking of Workplace Injuries and Illnesses - PDF
24 - 1904.7 - 82:35995-36005 - Jardon and Howard Technologies, Incorporated; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
25 - 1904.7 - 81:91792-91810 - Clarification of Employer's Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness - PDF
26 - 1904.7 - 81:88147-88167 - Prevention of Workplace Violence in Healthcare and SocialAssistance - PDF
27 - 1904.7 - 81:20680-20688 - Nucor Steel Connecticut Incorporated; Grant of a Permanent Variance - PDF
28 - 1904.7 - 81:12954-12966 - Traylor Bros., Inc.; Grant of a Permanent Variance - PDF
29 - 1904.7 - 80:75472-75480 - Nucor Steel Connecticut Incorporated; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
30 - 1904.7 - 80:45116-45131 - Clarification of Employer's Continuing Obligation To Make and Maintain an Accurate Record of Each Recordable Injury and Illness - PDF
31 - 1904.7 - 80:16440-16449 - Traylor/Skanska/Jay Dee Joint Venture: Grant of a Permanent Variance - PDF
32 - 1904.7 - 80:7636-7646 - Impregilo Healy Parsons Joint Venture; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
33 - 1904.7 - 79:73631-73641 - Traylor/Skanska/Jay Dee Joint Venture; Application for Permanent Variance and Interim Order; Grant of Interim Order; Request for Comments - PDF
34 - 1904.7 - 79:29809-29819 - Tully/OHL USA Joint Venture: Grant of a Permanent Variance - PDF
35 - 1904.7 - 66:52031-52034 - Occupational Injury and Illness Recording and Reporting Requirements - PDF
36 - 1904.7 - 66:2265-2273 - Notice of Initial Approval Determination; New Jersey Public Employee Only State Plan - PDF
# FAQ
1 Question 7-1 - The old rule required the recording of all occupational illnesses, regardless of severity. For example, a work-related skin rash was recorded even if it didn't result in medical treatment. Does the rule still capture these minor illness cases? - 1904.7
2 Question 7-2 - Does the size or degree of a burn determine recordability? - 1904.7
3 Question 7-3 - If an employee dies during surgery made necessary by a work-related injury or illness, is the case recordable? What if the surgery occurs weeks or months after the date of the injury or illness? - 1904.7
4 Question 7-4 - An employee hurts his or her left arm and is told by the doctor not to use the left arm for one week. The employee is able to perform all of his or her routine job functions using only the right arm (though at a slower pace and the employee is never required to use both arms to perform his or her job functions). Would this be considered restricted work? - 1904.7
5 Question 7-5 - Are surgical glues used to treat lacerations considered "first aid?" - 1904.7
6 Question 7-6 - Item N on the first aid list is "drinking fluids for relief of heat stress." Does this include administering intravenous (IV) fluids? - 1904.7
7 Question 7-7 - Is the use of a rigid finger guard considered first aid? - 1904.7
8 Question 7-8 - For medications such as Ibuprofen that are available in both prescription and non-prescription form, what is considered to be prescription strength? How is an employer to determine whether a non-prescription medication has been recommended at prescription strength for purposes of section 1904.7(b)(5)(i)(C)(ii)(A)? - 1904.7
9 Question 7-9 - If an employee who sustains a work-related injury requiring days away from work is terminated for drug use based on the results of a post-accident drug test, how is the case recorded? May the employer stop the day count upon termination of the employee for drug use under section 1904.7(b)(3) (viii)? - 1904.7
10 Question 7-10a - If a physician or other licensed health care professional recommends medical treatment, days away from work or restricted work activity as a result of a work-related injury or illness can the employer decline to record the case based on a contemporaneous second provider's opinion that the recommended medical treatment, days away from work or work restriction are unnecessary, if the employer believes the second opinion is more authoritative? - 1904.7
11 Question 7-10 - Once an employer has recorded a case involving days away from work, restricted work or medical treatment and the employee has returned to his regular work or has received the course of recommended medical treatment, is it permissible for the employer to delete the Log entry based on a physician's recommendation, made during a year-end review of the Log, that the days away from work, work restriction or medical treatment were not necessary? - 1904.7
12 Question 7-11 - Section 1904.7(b)(5)(ii) of the rule defines first aid, in part, as "removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means." What are "other simple means" of removing splinters that are considered first aid? - 1904.7
13 Question 7-12 - How long must a modification to a job last before it can be considered a permanent modification under section 1904.7(b)(4)(xi)? - 1904.7
14 Question 7-13 - If an employee loses his arm in a work-related accident and can never return to his job, how is the case recorded? Is the day count capped at 180 days? - 1904.7
15 Question 7-14 - If an employee who routinely works ten hours a day is restricted from working more than eight hours following a work-related injury, is the case recordable? - 1904.7
16 Question 7-15 - If an employee is exposed to chlorine or some other substance at work and oxygen is administered as a precautionary measure, is the case recordable? - 1904.7
17 Question 7-16 - Is the employer subject to a citation for violating section 1904.7(b)(4) (viii) if an employee fails to follow a recommended work restriction? - 1904.7
18 Question 7-17 - Are work-related cases involving chipped or broken teeth recordable? - 1904.7
19 Question 7-18 - How would the employer record the change on the OSHA 300 Log for an injury or illness after the injured worker reached the cap of 180 days for restricted work and then was assigned to "days away from work"? - 1904.7
20 Question 7-19 - Does the employer have to record a work-related injury and illness, if an employee experiences minor musculoskeletal discomfort, the health care professional determines that the employee is fully able to perform all of his or her routine job functions, but the employer assigns a work restriction to the injured employee? - 1904.7
21 Question 7-20 - Are injuries and illnesses recordable if they occurred during employment, but were not discovered until after the injured or ill employee was terminated or retired? - 1904.7
22 Question 7-21 - If an employee leaves the company after experiencing a work-related injury or illness that results in days away from work and/or days of restricted work/job transfer how would an employer record the case? - 1904.7
23 Question 7-22 - If an employee has an adverse reaction to a smallpox vaccination; is it recordable under OSHA's recordkeeping rule? - 1904.7
24 Question 7-23 - An employee has a work-related shoulder injury resulting in days of restricted work activity. While working on restricted duty, the employee sustains a foot injury which results in a different work restriction. How would the employer record these cases? - 1904.7
25 Question 7-24 - An employee is provided antibiotics for anthrax, although the employee does not test positive for exposure/infection. Is this a recordable event on the OSHA log? - 1904.7
26 Question 7-25 - An employee tests positive for anthrax exposure/infection and is provided antibiotics. Is this a recordable event on the OSHA log? - 1904.7
27 Question 7-26 - Are sutures used to treat lacerations considered "first aid?" - 1904.7
28 Question 7-27 - If an employee has x-rays or other diagnostic procedures, does that make a case recordable? - 1904.7
29 Question 7-28 - How many calendar days are to be counted in the case of a work-related fatal injury or illness? - 1904.7
30 Question 7-29 - An employee's normal shift is 6:00 PM to 2:30 AM. The employee starts his shift at 6:00PM on Monday and sustains a work-related injury at 12:30AM Tuesday. The injury results in the employee going to a physician who excuses the employee from work for Tuesday and allows the employee to return to work at 6:00 PM on Wednesday. Does this case involve days away from work or days of restricted work activity? - 1904.7
31 Question 7-30 - Are work-related human bites recordable on the OSHA form 300 when the skin is broken, and the wound is bleeding? - 1904.7
# Regulations
1 - 1904.7 - General recording criteria.
# Settlement Agreement
1 - - Industry Settlement Agreement - Building and Construction Trades Department - 04/06/2007