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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 21, 1999

Robert Bower
Medcor Medical Administrator
American NTN Bearing Mfg. Corp
1500 Holmes Road
Elgin, Illinois 60123

Dear Mr. Bower:

Thank you for your letter dated February 11, 1999 requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in the use of a topical skin adhesive for the treatment of lacerations. You ask if this would be considered a wound closure or a wound covering for OSHA recordkeeping purposes. I will respond by citing the regulations from 29 CFR Part 1904, and the Recordkeeping Guidelines for Occupational Injuries and Illnesses (Guidelines), by page and Q&A number(s), whenever possible.

In 1971, OSHA issued regulation 29 CFR Part 1904--Recording and Reporting Occupational Injuries and Illnesses, which states that occupational injuries involving medical treatment must be recorded on the OSHA No. 200­­Log and Summary of Occupational Injuries and Illnesses. In 1986, OSHA published the Recordkeeping Guidelines for Occupational Injuries and Illnesses to provide employers with supplemental instructions to the recordkeeping forms. On Pages 42-43 of the Guidelines, OSHA provides guidance for distinguishing between medical treatment and first aid.

"The following are generally considered medical treatment. Work-related injuries for which this type of treatment was provided or should have been provided are almost always recordable:...

    • Application of SUTURES (stitches)
    • Application of BUTTERFLY ADHESIVE DRESSING(S) or STERI STRIP(S) in lieu of sutures....

The following are generally considered first aid treatment (e.g., one-time treatment and subsequent observation of minor injuries) and should not be recorded if the work-related injury does not involve loss of consciousness, restriction of work or motion, or transfer to another job:

    • Application of BANDAGES(S) during any visit to medical personnel."

The concept that underlies the medical treatment vs. first aid distinction made between these types of treatments centers around the distinction between wound closures and wound coverings. Sutures (stitches), Steri Strips (TM), staples, butterfly adhesive dressings, etc. are all classified as wound closures to align the edges of wounds and to promote healing, while bandages (Band-Aids (TM), gauze pads, etc.) are wound coverings to prevent the invasion of bacteria and infection to an open wound. Any use of a wound closure is considered medical treatment for OSHA recordkeeping purposes, while the use of a wound covering is deemed to be first aid treatment.

This topical skin adhesive is used to close wounds such as lacerations. Therefore, use of this adhesive would be considered medical treatment for OSHA injury and illness recordkeeping purposes. A work-related laceration that is treated with the topical skin adhesive would have to be recorded on the OSHA Log 200.

I hope you find this information useful. If you have any further questions or comments, please contact the Division of Recordkeeping Requirements, at Area Code: (202) 693-1702.


Cheryle A. Greenaugh
Director, Directorate of Information Technology