Question: While breaking down cardboard boxes using a pocket knife, an employee cuts his arm. The occupational health nurse closes the wound using a product called zip stitch and the employee returns to work. Is it recordable?
Answer: YES. Zip stitch is a product designed to close a wound as an alternative to stitches, which are considered medical treatment beyond first aid. Wound coverings are typically considered first aid and wound closing devices are typically considered medical treatment.
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);
Letter of Interpretation: The regulation also provides that only two wound closing devices, Steri-Strips™ and butterfly bandages, are considered first aid treatments. Accordingly, since ZipStitch and Clozex are wound closing devices and are not included on the first aid list, they are considered medical treatment for OSHA record keeping. Also, please know that OSHA developed the first aid list in section 1904.5(b)(5)(ii) during the 2001 rulemaking that revised the agency’s recordkeeping regulation. Any addition or modification to the first aid list would need to be accomplished through notice and comment rulemaking.