Clarification on the use of a cold compression device is considered medical treatment.

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 https://www.osha.gov.

December 21, 2017

Eric Blankenheim
Blankenheim Services
1650 Tri Park Way
Suite A
Appleton, WI 54914

Dear Mr. Blankenheim:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. Specifically, you ask whether the use of a cold compression therapy device is medical treatment for OSHA recordkeeping purposes.

Requirements for injury cases which result in treatment with prescription medication.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 18, 1996

[Name Withheld]

Dear [Name Withheld]:

Thank you for your letter dated June 25, requesting clarification of the OSHA injury and illness recordkeeping requirements for injury cases which result in treatment with prescription medication.

An interpretation regarding the proper recording of Cumulative Trauma Disorder (CTD) cases on the OSHA Log 200.

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

July 23, 1996

Mr. William K. Principe
Constangy, Brooks & Smith
Suite 2400
230 Peachtree Street, N.W.
Atlanta, Georgia 30303-1557

Dear Mr. Principe:

Thank you for your letter dated June 11, requesting an interpretation regarding the proper recording of Cumulative Trauma Disorder (CTD) cases on the OSHA Log 200. As outlined in our February 9, 1993 letter to the Ford Motor Company, a new CTD case is established if the worker fails to return for "care" within 30 days and returns with similar complaints. "Care" includes the following:

The OSHA injury and illness recordkeeping requirements.

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 https://www.osha.gov.

July 24, 1996

Lon S. McDaniel, Ph.D.
Manager of Occupational Safety Health
and Quality Department
DynCorp of Colorado, Inc.
Post Office Box 464 T130D
Golden, Colorado 80402-0464

Dear Mr. McDaniel:

Interpretations concerning several OSHA injury and illness recordkeeping issues.

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 https://www.osha.gov.

August 15, 1996

Mr. Brad Brown Planning & Research Associate II Department of Labor Bureau of Labor Standards Research & Statistics Division State House Station #45 Augusta, Maine 04333-0045

Dear Brad:

Thank you for your letter dated July 31, requesting interpretations concerning several OSHA injury and illness recordkeeping issues. I will address each issue by first repeating the question and by referring to the appropriate Q&A and page numbers in the Recordkeeping Guidelines for Occupational Injuries and Illnesses.

Guidance on the proper recording of needlestick injuries on the OSHA 200 Log.

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 https://www.osha.gov.

September 20, 1996

Ms. Rosie Ward
Director of Human Resources
Holzer Medical Center
100 Jackson Pike
Gallipolis, Ohio 45631-1563

Dear Ms. Ward:

Thank you for your letter dated August 26, requesting guidance on the proper recording of needlestick injuries on the OSHA 200 Log. A work related needlestick injury shall be recorded if it meets one or more of the following requirements:

1. The incident results in a loss of consciousness, transfer to another job, or a work restriction, or

Recording of occupational injuries and illnesses occurring to inmate employees in Florida.

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 https://www.osha.gov.

July 18, 1996

Andrea Brinkman
Florida Institutional
Legal Services, Inc.
1110-C N.W. 8TH Avenue
Gainesville, Florida 32601

Dear Ms. Brinkman:

A reevaluation of recording injuries and illnesses associated with voluntary flu shot programs on the OSHA Log and Summary of Occupational Injuries and Illnesses.

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 https://www.osha.gov.

September 20, 1996

Mr. Larry M. Kreh
Manager, Ergonomics and Loss Prevention
PPG Industries, Inc.
Post Office Box 2009
Allison Park, Pennsylvania 15101

Dear Mr. Kreh:

The proper recording of cases involving work related stress for OSHA injury and illness recordkeeping purposes.

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 https://www.osha.gov.

September 9, 1996

Linda Ballas
Linda Ballas & Associates
4413 Copper Creek Lane
Toledo, Ohio 43615

Dear Ms. Ballas:

Thank you for your letter dated August 26, requesting an interpretation regarding the proper recording of cases involving work related stress for OSHA injury and illness recordkeeping purposes. Whenever possible, I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the appropriate page and Q&A numbers.

Conflicting medical opinions and determination of the recordability of a case.

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 https://www.osha.gov.

October 7, 1996

Wanda Padgett
Westinghouse
Savannah River Company
Post Office Box 816
Aiken, South Carolina 29802

Dear Ms. Padgett: