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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 2, 1997

John Thaler, CSP, CHMM
Manger, Occupational Safety and Industrial Hygiene
Sikorsky Aircraft Corporation
6900 Main Street - P.O. Box 9729
Stratford, CT 06497-9129

Dear Mr. Thaler:

Thank you for your letter dated July 22, 1997, requesting an interpretation regarding the recordability of an occupational injury.

The case described in your letter constitutes a subsequent application of a cold compress and is considered to be medical treatment for OSHA injury and illness recordkeeping purposes. The fact that the ice pack is applied twice is the determining factor in making it medical treatment rather than first aid.

As indicated on pages 42 and 43 (Q&A F3) of the Recordkeeping Guidelines, the treatment is the main factor to consider in distinguishing medical treatment from first aid, not the person who is administering it. In distinguishing between medical treatment and first aid, Congress intended to focus on the seriousness of the injury. Doctors or medical personnel often provide first aid treatment for minor injuries; nonmedical personnel often provide medical treatment for certain injuries that are relatively serious in nature.

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





July 22, 1997

Mr. Stephen Newell
Director, Office of Statistics
US Department of Labor, OSHA
Rm # N3507
200 Constitution Avenue, N.W.
Washington, D.C. 20210

Dear Mr. Newell

I am requesting that your office review whether or not the following scenario would be considered an OSHA recordable non-lost time case under OSHA Recordkeeping requirements.

An employee who works at a small satellite plant strikes his leg and receives a bruise. He reports to the site security guard who provides a chemical cold pack to the bruise and the person returns to work. Later the same day the employee feels that the bruise is still sore and this time is sent to the main plant's Medical Department 10 miles away. He receives an additional cold pack by the plant nurse.

Does this second activity on the part of the employee constitute a subsequent application of a hot or cold compress as described on page 43 of the Recordkeeping Guidelines or is this considered first aid? What if the ice pack had been applied in both instances by medical personnel on the same day?

Thank you for your consideration in this matter.


John Thaler, CSP, CHMM
Manager, Occupational Safety and Industrial Hygiene
Sikorsky Aircraft