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OSHA interpretation · 1993-10-28

Several OSHA injury and illness recordkeeping issues.

← All interpretations§ 1904

OSHA’s standing caveat

Interpretation letters explain existing requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Enforcement guidance may be affected by later changes to OSHA rules, and a letter addresses the facts it was given — not necessarily yours.

October 28, 1993 David F. Coble, MS, CSP Vice President, Safety ELB 605 Eastowne Drive Chapel Hill, North Carolina 27514 Dear Mr. Coble: Thank you for your letter dated September 27, requesting an interpretation of several OSHA injury and illness recordkeeping issues. I will respond by first repeating each question then addressing it. Whenever possible I will reference the Recordkeeping Guidelines for Occupational Injuries and Illnesses by stating the page and Q&A numbers. Q1 If a doctor diagnoses "cumulative trauma of the back", is this an illness or an injury? A1 Back cases should always be classified as injuries and are recordable if they meet the injury criteria. This generalization was made to keep the recordkeeping determinations as simple and equitable as possible (page 38, Q&A D-4). Q2 At what point does acupuncture and massage treatment become recordable? A2 Any treatment of acupuncture is to be considered medical treatment for OSHA injury and illness recordkeeping purposes. It is generally performed to relieve the discomfort associated with painful disorders, requires a high degree of skill since it involves piercing specific peripheral nerves, and cannot be performed by a lay person. For OSHA injury and illness recordkeeping purposes, massage therapy is evaluated as a form of physical therapy. Physical therapies are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel (page 43, Guidelines). Q3 At what point does a treatment called "reflexology" become recordable? A3 For OSHA injury and illness recordkeeping purposes, reflexology, defined as a form of massage therapy to the feet, is considered medical treatment when performed during a second or subsequent visit to medical personnel. I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463. Sincerely, Bob Whitmore Chief Division of Recordkeeping Requirements

Reproduced verbatim from osha.gov. US Government work, public domain (17 U.S.C. § 105).

Other letters on the same sections

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Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.