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OSHA interpretation · 1995-08-02

The classification of medical treatment for OSHA injury and illness recordkeeping purposes.

← 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.

August 2, 1995 James F. Smith Mountain Technical Center 10100 West Ute Avenue Post Office Box 625005 Littleton, Colorado 80162-5005 Dear Mr. Smith: Thank you for your letter dated June 15, requesting an interpretation regarding the classification of medical treatment for OSHA injury and illness recordkeeping purposes. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide. For OSHA injury and illness recordkeeping purposes, use of hot or cold therapy or physical therapy on first visit to a health care professional should be considered first aid treatment (regardless of the number of modalities given). Physical therapies and heat/cold treatments are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel (see page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses ). 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.