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OSHA interpretation · 1997-09-02

Multiple applications of a cold compress may be recordable.

← 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.

September 2, 1997 John Thaler, CSP, CHMM Manger, Occupational Safety and Industrial Hygiene Sikorsky Aircraft Corporation 6900 Main Street - P.O. Box 9729 Stratford, CT 06497-9129 Dear Mr. Thaler: Thank you for your letter dated July 22, 1997, requesting an interpretation regarding the recordability of an occupational injury. The case described in your letter constitutes a subsequent application of a cold compress and is considered to be medical treatment for OSHA injury and illness recordkeeping purposes. The fact that the ice pack is applied twice is the determining factor in making it medical treatment rather than first aid. As indicated on pages 42 and 43 (Q&A F3) of the Recordkeeping Guidelines , the treatment is the main factor to consider in distinguishing medical treatment from first aid, not the person who is administering it. In distinguishing between medical treatment and first aid, Congress intended to focus on the seriousness of the injury. Doctors or medical personnel often provide first aid treatment for minor injuries; nonmedical personnel often provide medical treatment for certain injuries that are relatively serious in nature. 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 July 22, 1997 Mr. Stephen Newell Director, Office of Statistics US Department of Labor, OSHA Rm # N3507 200 Constitution Avenue, N.W. Washington, D.C. 20210 Dear Mr. Newell I am requesting that your office review whether or not the following scenario would be considered an OSHA recordable non-lost time case under OSHA Recordkeeping requirements. An employee who works at a small satellite plant strikes his leg and receives a bruise. He reports to the site security guard who provides a chemical cold pack to the bruise and the person returns to work. Later the same day the employee feels that the bruise is still sore and this time is sent to the main plant's Medical Department 10 miles away. He receives an additional cold pack by the plant nurse. Does this second activity on the part of the employee constitute a subsequent application of a hot or cold compress as described on page 43 of the Recordkeeping Guidelines or is this considered first aid? What if the ice pack had been applied in both instances by medical personnel on the same day? Thank you for your consideration in this matter. Sincerely, John Thaler, CSP, CHMM Manager, Occupational Safety and Industrial Hygiene Sikorsky Aircraft

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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