Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

August 27, 1991


                   Area Director; Bismarck, North Dakota

THRU:               LEO CAREY
                   Director, Office of Field Operations

                   BYRON R. CHADWICK
                   Region VII Administrator
                   Attention: Cindi Cross
                              Region VII
                              Recordkeeping Coordinator

FROM:               STEPHEN A. NEWELL
                   Acting Director, Office of Statistics

SUBJECT:            Recordkeeping Question From John Morrell Inc.

The most comprehensive guidance for the recording of CTDs on the OSHA 200 Log is found on pages 14 and 15 of the Ergonomics Program Management Guidelines For Meatpacking Plants. The ergonomics guidelines state that a CTD exists if there is at least one physical finding OR at least one subjective symptom combined with 1) medical treatment, 2) lost workdays (includes restricted work activity), or 3) transfer/rotation to another job.

The definition of lost workdays, restricted work activity, and medical treatment used in the meatpacking guidelines are the same as those found in the Recordkeeping Guidelines For Occupational Injuries and Illnesses. On page 42 of the recordkeeping guidelines medical treatment is defined as "any treatment, other than first aid treatment, administered to injured employees". First aid treatment is then defined as "any one-time treatment, and any follow-up visit for the purpose of observation of minor scratches, cuts, burns, splinters and so forth, which do not ordinarily require medical care". On page 43 of the recordkeeping guidelines a list containing examples of medical treatment and first aid treatment are provided.

The medical treatment/first aid lists address several of the treatments mentioned in your letter to Mr. Hairston. The use of cold compresses (including ice packs) during second or subsequent visit to medical personnel is considered medical treatment. The use of nonprescription medications (aspirin, over the counter ibuprofren, etc.) is considered first aid treatment, regardless of the quantity of such medications used. The use of prescription medications (medications for which a physician's prescription is required) is considered medical treatment if more than a single dose is used for minor injury or discomfort.

The first aid/medical treatment lists do not provide comprehensive guidance concerning the use of splints and/or wraps. The only mention of the subject is that the use of elastic bandages during first visit to medical personnel is considered first aid treatment. Our interpretation of the recordkeeping guidelines is that the use of casts, splints or orthopedic devices designed to immobilize a body part are considered medical treatment, while wraps or non-constraining devices such as wristlets are considered first aid treatment, regardless of how long or how often they are used.