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OSHA interpretation · 2002-08-08

Use of liquid bandages on wounds is considered first aid.

← All interpretations§ 1904§ 1904.7(b)(5)(ii)

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.

Where this letter fits

OSHA issued this letter on 2002-08-08. It interprets the following provisions of 29 CFR Part 1904:

  • § 1904.7 — General recording criteria (33 OSHA letters cite this section)

Browse every letter on the interpretations index, read worked examples on the scenarios page, or see the first-aid list that 29 CFR 1904.7 turns on.

August 8, 2002 Mr. Carl O. Sall, CIH Director of Occupational Safety and Health Compliance Comprehensive Health Services Incorporated 8229 Boone Boulevard; Suite 700 Vienna, Virginia 22182-2623 Dear Mr. Sall: This is in response to your letter dated August 8, 2002. Thank you for your comments pertaining to the Occupational Safety and Health Administration's (OSHA) Injury and Illness Recording and Reporting requirements contained in 29 CFR Part 1904. Specifically, you ask OSHA to clarify whether an injury and illness case which resulted in treatment with Band-Aid Brand Liquid Bandage would be considered first aid or medical treatment. The concept that underlies the medical treatment vs. first aid distinction made between this type of treatment centers around the basic difference between wound closures and wound coverings. The recordkeeping rule defines first aid under section 1904.7(b)(5)(ii)(D), "Using wound coverings, such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-strips™ (other wound closing devices, such as sutures, staples, etc. are considered medical treatment)." Therefore, the use of wound coverings, like Band-Aid Brand Liquid Bandage™ is deemed to be first aid treatment. I hope that you find this information useful. Thank you for your interest in occupational safety and health and OSHA. If you have any further questions, please contact the Division of Recordkeeping Requirements at 202-693-1702. Sincerely, John L. Henshaw Assistant Secretary [Corrected 8/8/2004]

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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