- Standard Number:
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 https://www.osha.gov.
February 18, 1993
David F. Coble, Ph.D. CSP
Vise President, Safety ELB
605 Eastowne Drive
Chapel Hill, North Carolina 27514
Dear Mr. Coble:
Thank you for your letter dated January 25, requesting an interpretation of several OSHA injury and illness recordkeeping issues. I will respond by first repeating each question then addressing it. Whenever possible I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the page and Q&A numbers.
Q1 I understand that you stated at the National Safety Congress that the use of an elastic or Ace bandage for treatment of a work related injury is not recordable. Could you confirm this or state when elastic bandage usage makes the case recordable?
A1 This question revolves around the issue of medical treatment vs first aid for various orthopedic devices. Our interpretation of the recordkeeping Guidelines is that the use of casts, splints or orthopedic devices designed to immobilize a body part are generally considered medical treatment. Wraps or non-constraining devices such as wristlets or elastic bandages are generally considered first aid treatment. Please keep in mind, however, that the distinction between first aid and medical treatment is based upon the type of treatment either actually provided or clearly required, even if not provided. If a health care provider "prescribed" a device to immobilize the wrist, the case should be evaluated as one involving medical treatment. (page 44, Q&A F-5)
Q2 There is still confusion about recording of pinhead size second degree burns. Is one pinhead sized burn recordable? Are multiple pinhead sized burns recordable? If no treatment is provided, does this have an impact on recordability? At this time, is there any official size to trigger recording of second degree burns?
A2 Any work related second degree burn that is larger than a pinhead or any work related third degree burn (regardless of size) is recordable. As found on page 42 of the Guidelines, a non-minor injury is one that results in damage to the physical structure of a nonsuperficial nature. All work related non-minor injuries must be recorded. Work related first degree burns are considered minor injuries and not recordable by nature. However, first degree burns and pinhead sized second degree burns, like any other minor injury, are recordable if medical treatment is provided.
I hope you find this information useful. If you have any further questions, please contact my staff at Area Code (202) 219-6463.
Stephen A. Newell Director
Office of Statistics