- 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.
August 3, 1993
Mr. Larry M. Kreh Manager,
Ergonomics and Loss Prevention
PPG Industries, Inc.
Post Office Box 2009
Allison Park, Pennsylvania 15101
Dear Mr. Kreh:
Thank you for your facsimile dated July 19, requesting interpretations as to when orthopedic devices constitute medical treatment for OSHA injury and illness recordkeeping purposes. I will repeat each of your questions and follow with my response.
Q1 Employee goes to medical department with subjective symptoms "My wrist hurts". A somewhat "flexible" wrist splint is given to the employee and the employee can do all of their job. Non-recordable?
A1 A cumulative trauma disorder is recordable 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. Examples of physical findings include positive Tinel's, Phalen's, or Finkelstein's tests; or swelling, redness or deformity; or loss of motion. Subjective symptoms include pain, numbness, tingling, aching, stiffness, or burning.
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.
If by "somewhat flexible" you mean that the splint does not immobilize the wrist, then the case would not be recordable.
Q2 Same scenario as 1., but the employee is given a wrist splint which immobilizes the joint. Recordable?
A2 Yes, due to a subjective symptom coupled with medical treatment.
Q3 Employee reports to medical complaining of wrist pain and is given a flexible wrist splint, but can only perform 80% of their job while wearing the wrist splint. Recordable?
A3 Yes, due to a subjective symptom coupled with restricted work activity.
I hope you find this information useful. If you have any further questions, please call my staff at Area Code (202) 219-6463.
Stephen A. Newell Director
Office of Statistics