New Interpretation letter on First Aid
https://www.osha.gov/laws-regs/standardinterpretations/2024-05-02
OSHA published a new standard interpretation called: Enforcement Guidance Under OSHA's Recordkeeping Regulation When First Aid, Active Release Techniques (ART), and Exercise/Stretching Are Used to Treat Musculoskeletal Injuries and Illnesses
I found one section rather interesting.
For example, if an employee sustains a work-related injury and a physician or other licensed health care professional recommends that the employee interrupts their work activities to rest every half hour; use ice for 15 minutes every hour; elevate the injured body part as much as possible; or work as tolerated, then that employee would have worked a partial shift, and the case is recordable. Note that the employer does not have to record restricted work activity if imposed only for the day on which the injury or the illness occurred.
When I was at Amazon we would often treat injuries in house with ice or stretching sometimes multiple times a day. It seems this interpretation means we should have recorded these injuries. I have never done that.
What do you guys think?
Comments (3)
Yep, that's the way I interpret it (that the injuries/illnesses you had at Amazon WOULD be recordable). Another important part of that guidance is that the ART (or any other form of massage) can be administered by anyone, so it doesn't have to be a licensed massage therapist or something similar.
It's important to note that if the ART is conducted after hours and doesn't involve the time away from work like in the scenario you mentioned, and ART is the ONLY treatment administered, then it would NOT be an OSHA recordable. See below.
"In 2006, OSHA concluded that ART is "massage" for purposes of OSHA recordkeeping. Since massage therapy is included on the list of first aid treatments in section 1904.7(b)(5)(ii), if the only treatment an injured worker receives is ART, the employer is not required to record the injury. OSHA considers ART to be first aid regardless of the professional status of the person providing the treatment."
Being treated in house I would say it is not a recordable. Unless you had a healthcare professional on-site treating these.