Standard Interpretations - Table of Contents
• Standard Number: 1904.7(b)(5)(ii); 1904.7(b)(5)(ii)(M); 1904.7(b)(5)(iii)

May 20, 2011

Mr. Paul Bragenzer
1415 Rothbury Dr.
Grand Rapids, MI 49505

Dear Mr. Bragenzer:

Thank you for your February 2011 letter to the Occupational Safety and Health Administration (OSHA) regarding the recordkeeping regulation contained in 29 CFR Part 1904 - Recording and Reporting Occupational Injuries and Illnesses. In an effort to provide the public with prompt and accurate responses, we developed and continue to refine a set of Frequently Asked Questions (FAQ), in addition to maintaining a log of Letters of Interpretation (LOI) on the OSHA Recordkeeping web site.

Your letter asks OSHA to clarify whether an exercise regime directed by a Certified Athletic Trainer (ATC) would constitute "first aid" or "medical treatment" for OSHA injury and illness recordkeeping purposes. In general, if the ATC recommends exercise to an employee who exhibits any signs or symptoms of a work related injury, the case involves medical treatment and is a recordable case.

OSHA discussed the issue of therapeutic exercise in the preamble to the final rule revising OSHA's injury and illness recordkeeping regulation. See, 66 FR 5992, January 19, 2001. OSHA stated that it considers therapeutic exercise as a form of physical therapy and intentionally did not include it on the list of first aid treatments in Section 1904.7(b)(5)(ii). Section 1904.7(b)(5)(ii)(M) states that physical therapy or chiropractic treatment are considered medical treatment for OSHA recordkeeping purposes and are not considered first aid. Section 1904.7(b)(5)(iii) goes on to state that the treatments included in Section 1904.7(b)(5)(ii) is a comprehensive list of first aid treatments. Any treatment not included on this list is not considered first aid for OSHA recordkeeping purposes.