Q43 - Warm Wax Treatment

Question: 

An assembly line employee reports aching pain in his hands to the third party Occupational Health Nurse that works on site. The nurse instructs the employee to take over the counter Naproxen per the instructions on the packaging and also encourages the employee to adhere to the company stretching program that he has been trained and is considered a condition of employment upon hire. The nurse also has the employee soak his hands in warm wax on each break and at the end of the employee’s shift.  Is it recordable?

Answer:

NO. Over the counter Naproxen and warm wax treatment does not meet OSHA recordable criteria. Prescribed stretching is considered therapeutic treatment, which is recordable. However, the stretching techniques were already a part of the company program and were not prescribed; rather, program participation was encouraged.

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)(A)

Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);

 

1904.7(b)(5)(ii)(E)

Using hot or cold therapy;

 

Therapeutic Interpretation Letter

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