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Heat and cold therapy in injury recordkeeping

Summary An employer asked how to classify hot, cold or physical therapy for injury and illness logs. OSHA said treatment at the first health care visit counted as first aid under its then-current guidelines, while treatment at a later visit counted as medical treatment. OSHA labels the letter an archive document.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1995-08-02
Date issued
August 2, 1995
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1904 Recordkeeping First Aid
Source
View the official document

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The current status of this document is unclear
OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 2, 1995

James F. Smith
Mountain Technical Center
[Recipient address omitted]
Dear Mr. Smith:

Thank you for your letter dated June 15, requesting an interpretation regarding the classification of medical treatment for OSHA injury and illness recordkeeping purposes. Your letter was forwarded to my Office from the Directorate of Compliance Programs. The Division of Recordkeeping Requirements is responsible for the administration of the injury and illness recordkeeping system nationwide.

For OSHA injury and illness recordkeeping purposes, use of hot or cold therapy or physical therapy on first visit to a health care professional should be considered first aid treatment (regardless of the number of modalities given). Physical therapies and heat/cold treatments are considered medical treatment only when they are administered on a second or subsequent visit to medical personnel (see page 43 of the Recordkeeping Guidelines for Occupational Injuries and Illnesses).

I hope you find this information useful. If you have any further questions, please contact us at Area Code (202) 219-6463.

Sincerely,
Bob Whitmore
Chief
Division of Recordkeeping Requirements

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