In an April 2016 Interpretation Letter, which was recently made publically available, OSHA responded to a question about medical treatment beyond first aid for recordkeeping purposes. The incident in question involved an employee who experienced wrist pain after working at a computer. Before being seen at the occupational health clinic, the employee bought and used a rigid wrist brace. The doctor said that the brace was not necessary but recommended that the employee continue to wear it if it was relieving the pain. The requester wanted to know whether this constituted medical treatment.
In responding, OSHA stated that the recordkeeping criteria is met if the treatment is “directed or recommended by the employer or a health care professional.” In this particular situation, because the doctor recommended the employee continue wearing the brace if it relieved pain, OSHA determined that this constituted medical treatment beyond first aid. Since OSHA does not generally consider self-treatment or self-medication to amount to medical treatment beyond first aid, had the doctor provided no opinion on the use of the wrist brace the work-related injury would not have been recordable.