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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 2, 1995

James F. Smith
Mountain Technical Center
10100 West Ute Avenue
Post Office Box 625005
Littleton, Colorado 80162-5005

Dear Mr. Smith:

Thank you for your letter dated June 15, requesting an interpretation regarding the classification of medical treatment for OSHA injury and illness recordkeeping purposes. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

For OSHA injury and illness recordkeeping purposes, use of hot or cold therapy or physical therapy on first visit to a health care professional should be considered first aid treatment (regardless of the number of modalities given). Physical therapies and heat/cold treatments are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel (see page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).

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