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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

September 20, 1996

Ms. Lisann Rolle
Supervisor, BLSI Washington
Department of Labor and Industries
Post Office Box 44631
Olympia, Washington 98504-4631

Dear Ms. Rolle:

Thank you for your letter dated September 4, requesting an interpretation regarding the evaluation of chiropractic treatments as medical treatment for OSHA injury and illness recordkeeping purposes. The determining factor is not the number of visits to the chiropractor, but the number of treatments given to the injured worker. A series of treatments (two or more) by a chiropractor is considered medical treatment. A single treatment is considered first aid (Q&A F-14, page 45 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses ). The following scenarios are examples of chiropractic treatments that are considered medical treatment: 1) during a single visit to a chiropractor an employee is given some form of treatment modality in addition to a spinal manipulation; 2) an employee receives a single treatment on each of two separate visits. The following scenario is an example of a chiropractic treatment considered first aid: an employee is examined on the first visit to the chiropractor (with no treatment) and receives a single treatment on the second visit.

The scenario outlined in your letter (single treatment during a single visit to the chiropractor) is considered first aid for OSHA injury and illness recordkeeping purposes.

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