August 27, 1991
MEMORANDUM FOR: BRUCE C. BEELMAN
Area Director; Bismarck, North Dakota
THRU: LEO CAREY
Director, Office of Field Operations
BYRON R. CHADWICK
Region VII Administrator
Attention: Cindi Cross
FROM: STEPHEN A. NEWELL
Acting Director, Office of Statistics
SUBJECT: Recordkeeping Question From John Morrell Inc.
The most comprehensive guidance for the recording of CTDs on the OSHA 200
Log is found on pages 14 and 15 of the Ergonomics Program Management
Guidelines For Meatpacking Plants. The ergonomics guidelines state that
a CTD exists if there is at least one physical finding OR at least one
subjective symptom combined with 1) medical treatment, 2) lost workdays
(includes restricted work activity), or 3) transfer/rotation to another job.
The definition of lost workdays, restricted work activity, and medical
treatment used in the meatpacking guidelines are the same as those found in
the Recordkeeping Guidelines For Occupational Injuries and Illnesses.
On page 42 of the recordkeeping guidelines medical treatment is defined as
"any treatment, other than first aid treatment, administered to injured
employees". First aid treatment is then defined as "any one-time treatment,
and any follow-up visit for the purpose of observation of minor scratches,
cuts, burns, splinters and so forth, which do not ordinarily require medical
care". On page 43 of the recordkeeping guidelines a list containing examples
of medical treatment and first aid treatment are provided.
The medical treatment/first aid lists address several of the treatments
mentioned in your letter to Mr. Hairston. The use of cold compresses
(including ice packs) during second or subsequent visit to medical personnel
is considered medical treatment. The use of nonprescription medications
(aspirin, over the counter ibuprofren, etc.) is considered first aid
treatment, regardless of the quantity of such medications used. The use of
prescription medications (medications for which a physician's prescription is
required) is considered medical treatment if more than a single dose is used
for minor injury or discomfort.
The first aid/medical treatment lists do not provide comprehensive guidance
concerning the use of splints and/or wraps. The only mention of the subject
is that the use of elastic bandages during first visit to medical personnel
is considered first aid treatment. Our interpretation of the recordkeeping
guidelines is that the use of casts, splints or orthopedic devices designed
to immobilize a body part are considered medical treatment, while wraps or
non-constraining devices such as wristlets are considered first aid
treatment, regardless of how long or how often they are used.