Use of Zipstitich and Clozex to close a wound is medical treatment beyond first-aid.

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 9, 2019

Kate Frank
Ascension Employer Solutions
1901 Westwood Center Blvd.
Wausau, WI 54401

Dear Ms. Frank:

Thank you for your letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. You asked whether the use of novel wound closure devices such as Clozex and ZipStitch for the treatment of minor lacerations is considered medical treatment beyond first aid for OSHA recordkeeping purposes.

Clarification of soft tissue massage

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.

May 23, 2019

Sharon Dunn, PT, PhD
President
American Physical Therapy Association
1111 N. Fairfax Street
Alexandria, VA 22314

 

Dear Dr. Dunn:

 

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 other techniques of soft tissue massage that are similar to Active Release Techniques (ART) would be considered first-aid for purposes of OSHA recordkeeping.

Clarification on the use of cold therapy.

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.

November 14, 2018

Scott Sailor
NATA
1620 Valwood Parkway
Suite 115
Carrollton, Texas 75006

 

Dear Mr. Sailor:

 

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 OSHA to reevaluate its classification of cold compression therapy as medical treatment for recordkeeping purposes.

Determining whether Active Release Techniques (ART) constitutes first-aid or 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.

JUL 24 2006

Michael Leahy, DC
Active Release Techniques, LLC
175 South Union Blvd.
Suite 230
Colorado Springs, Colorado 80910

 

Dear Dr. Leahy

 

Clarification on the use of a cold therapy only setting on a therapeutic device is first-aid

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 9, 2018

Tomasina Barton
CoolSystems, Inc. DBA Game Ready
1800 Sutter St. Suite 500
Concord, California 94520

Dear Mr. Barton:

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 therapy only setting on a therapeutic device is considered first aid for purposes of OSHA recordkeeping.

Use of glue to close a wound is medical treatment; prescription antibiotics/antiseptics for preventive treatment of a wound is 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.

August 26, 2004

Mr. Ronald Bjork
Manager, Safety, Health & Security
CNH America LLC
East Moline Plant
1100 Third Street
East Moline, IL 61244

Dear Mr. Bjork:

This is in response to your letter of April 21, 2004 requesting clarification whether two types of treatments constitute first aid or medical treatment for purposes of applying OSHA's recordkeeping rule.