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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 18, 1993

Ms. Susan A. Tate, R.N.
The William Carter Company
2810 North Expressway
Harlingen, Texas 78552

Dear Ms. Tate:

Thank you for your letter dated July 1, requesting an interpretation regarding the recordability of cases involving the use of a hand held massager. Your letter was forwarded to my office by Gilbert Saulter of the Dallas Regional Office. I will address your letter under the assumption that you are referring to the OSHA Log 200 when referring to "logging" and to a "first aid record". Whenever possible, I will refer to the enclosed Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Q&A B-6 on page 30 of the Guidelines states "Entries on the log...should be made only when the exposure results in a recordable work injury or illness." If there are no symptoms or abnormal health conditions, then there is no recordable case, regardless of use of the massager. Furthermore, Q&A B-9 on page 30 addresses the situation of receiving preventative care when not injured or ill. This care does not make a case recordable. If, however, the employee is symptomatic, the medical treatment criteria outlined below must be applied to determine if the case is recordable or not.

For OSHA injury and illness recordkeeping purposes, massage therapy is evaluated as a form of physical therapy. Physical therapies are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel, including self-administered treatment when made available to employees by their employer. To be considered medical treatment, self-administered treatment must be performed at the medical facility or on the employer's premises when provided by the employer. An example would be hand held massagers located near the employee's work station to be applied when they are feeling discomfort. The treatment does not have to be supervised by medical personnel to be considered medical treatment. On the other hand, if the treatment is self-administered at home or if the treatment was given only on the initial visit to medical personnel, it is considered first aid and would not constitute medical treatment (page 43, Guidelines).

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