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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

October 28, 1993

David F. Coble, MS, CSP
Vice President, Safety ELB
605 Eastowne Drive
Chapel Hill, North Carolina 27514

Dear Mr. Coble:

Thank you for your letter dated September 27, 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 If a doctor diagnoses "cumulative trauma of the back", is this an illness or an injury?

A1 Back cases should always be classified as injuries and are recordable if they meet the injury criteria. This generalization was made to keep the recordkeeping determinations as simple and equitable as possible (page 38, Q&A D-4).

Q2 At what point does acupuncture and massage treatment become recordable?

A2 Any treatment of acupuncture is to be considered medical treatment for OSHA injury and illness recordkeeping purposes. It is generally performed to relieve the discomfort associated with painful disorders, requires a high degree of skill since it involves piercing specific peripheral nerves, and cannot be performed by a lay person.

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 (page 43, Guidelines).

Q3 At what point does a treatment called "reflexology" become recordable?

A3 For OSHA injury and illness recordkeeping purposes, reflexology, defined as a form of massage therapy to the feet, is considered medical treatment when performed during a second or subsequent visit to medical personnel.

I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.


Bob Whitmore
Division of Recordkeeping Requirements