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.