An office employee reports a pain in their neck after spending many hours at a new desk next to their supervisor. The occupational health nurse provides soft tissue massage and performs an ergonomic evaluation of their work station to prevent future problems. Is it recordable?
NO. Soft tissue massage is considered first aid treatment and is therefore not recordable.
1904.7(b)(5)(ii) What is "first aid"? For the purposes of Part 1904, "first aid" means the following:
1904.7(b)(5)(ii)(M) Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes);
Letter of Interpretation Section 1904.7(b)(5) of OSHA’s recordkeeping regulation requires employers to record work-related injuries and illnesses that result in medical treatment beyond first aid. Under Part 1904, medical treatment does not include "first aid" as defined in paragraph 1904.7(b)(5)(ii). The section specifically states that "using massages" is first aid. See, subparagraph (M). Section 1904.7(b)(5)(iii) goes on to state that the list of first aid treatments in section 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on the list is not considered first aid for OSHA recordkeeping purposes.
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