Whether manual joint manipulation is considered first aid or medical treatment for recordkeeping purposes

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.

November 16, 2009

Mr. Ron C. Lewis
Manager, Operational Excellence, Support & Reviews
Chevron Phillips
10001 Six Pines Drive
Room 4118
The Woodlands, TX  77380
Dear Mr. Lewis:

Clarification of the term self-inflicted as used in the Recordkeeping standard

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.

March 31, 2009

Mr. Victor E. Brame
HSE Engineer
Honeywell Analytics, Inc.
405 Barclay Boulevard
Lincolnshire, IL  60069

Dear Mr. Brame:

Counting restricted days for a part-time employee

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.

March 30, 2009

Mr. Jay R. Gnadt, CSP, CRM
Lockton Companies of Dallas, Inc.
1814 Childress Lane
Allen, TX  75013

Dear Mr. Gnadt:

Clarification on whether an exercise regime is first aid or medical treatment

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 20, 2011

Mr. Paul Bragenzer
1415 Rothbury Dr.
Grand Rapids, MI 49505

Dear Mr. Bragenzer:

Clarification on recordability when trigger point injections are used for medical treatment and for diagnostic procedures

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.

April 18, 2011

Dr. Jay Alexius
All Industrial Medical Services
855 Belanger Street Suite 207
Houma, LA  70360

Dear Dr. Alexius:

Clarification on pre-existing conditions and recordable incidents

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 5, 2010

Mr. Corby Autin
President
A&E Compliance Solutions, LLC
P.O. Box 475
Galliano, LA  70354

Dear Mr. Autin:

Recording an absence as days away when PLHCP recommends the employee return to work.

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.

March 22, 2011

Mr. William K. Principe
Suite 2400
230 Peachtree St., NW
Atlanta, Georgia 3030-1557

Dear Mr. Principe,

Therapeutic exercise is considered medical treatment for recordkeeping purposes.

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 21, 2010

Dr. Betsy Buehrer
3M Corporate Occupational Medicine
3M Center
Building 220-6W-08
St. Paul, Minnesota 55133-3428

Mr. Michael Nash
3M General Counsel
3M Center
P.O. Box 33428
St. Paul Minnesota 55133-3428

Dear Dr. Buehrer and Mr. Nash,

Recording days away and/or restricted work activity when employee is able to work part of a shift.

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.

September 7, 2010

Ms. Linda Ballas
Linda Ballas & Associates
7129 Nightingale Drive
Holland, OH 43528

Dear Ms. Ballas:

Use of kinesiology tape is not considered medical treatment beyond first aid.

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.

July 6, 2015

Jim Thornton
National Athletic Trainers' Association
1620 Valwood Parkway, Suite 115
Carrollton, TX 75006

Dear Mr. Thornton:

Thank you for your letter dated January 27, 2015, to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR 1904 — Recording and Reporting Occupational Injuries and Illnesses. Specifically, you asked OSHA to reconsider its interpretation regarding the use of kinesiology tape.