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Repeat cold-compress treatment on former OSHA injury logs

Summary An aircraft employer asked whether a second cold pack for the same workplace bruise changed a case from first aid to medical treatment. Under OSHA’s former recordkeeping guidance, the letter said the repeat application was medical treatment and that the provider’s job title did not decide the question. OSHA marks this letter as archived and says it may no longer represent agency policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-09-02-0
Date issued
September 2, 1997
Status
Archived by the agency
OSHA labels this an archive document and says it may no longer represent agency policy; the page does not state a withdrawal or replacement.
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OSHA labels this an archive document and says it may no longer represent agency policy; the page does not state a withdrawal or replacement. 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 Treat this page as historical context, not current guidance, and verify current law before relying on anything here.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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

September 2, 1997

John Thaler, CSP, CHMM
Manger, Occupational Safety and Industrial Hygiene
Sikorsky Aircraft Corporation
[Recipient address omitted]
Dear Mr. Thaler:

Thank you for your letter dated July 22, 1997, requesting an interpretation regarding the recordability of an occupational injury.

The case described in your letter constitutes a subsequent application of a cold compress and is considered to be medical treatment for OSHA injury and illness recordkeeping purposes. The fact that the ice pack is applied twice is the determining factor in making it medical treatment rather than first aid.

As indicated on pages 42 and 43 (Q&A F3) of the Recordkeeping Guidelines, the treatment is the main factor to consider in distinguishing medical treatment from first aid, not the person who is administering it. In distinguishing between medical treatment and first aid, Congress intended to focus on the seriousness of the injury. Doctors or medical personnel often provide first aid treatment for minor injuries; nonmedical personnel often provide medical treatment for certain injuries that are relatively serious in nature.

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

[Requester letter reproduced on OSHA page; omitted here.]

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