Is It Recordable?
Scenario Q43

Warm Wax Treatment: is it recordable?

Verdict: Not recordable
Published 2020-04-27

Question

An assembly line employee reports aching pain in his hands to the third party Occupational Health Nurse that works on site. The nurse instructs the employee to take over the counter Naproxen per the instructions on the packaging and also encourages the employee to adhere to the company stretching program that he has been trained and is considered a condition of employment upon hire. The nurse also has the employee soak his hands in warm wax on each break and at the end of the employee’s shift. Is it recordable?

Answer

NO. Over the counter Naproxen and warm wax treatment does not meet OSHA recordable criteria. Prescribed stretching is considered therapeutic treatment, which is recordable. However, the stretching techniques were already a part of the company program and were not prescribed; rather, program participation was encouraged.
1904.7(b)(5)(ii)
What is "first aid"? For the purposes of Part 1904, "first aid" means the following:
1904.7(b)(5)(ii)(A)
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
1904.7(b)(5)(ii)(E)
Using hot or cold therapy;

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(ii)

https://www.osha.gov/laws-regs/standardinterpretations/2010-05-21

Illustration for the scenario: Warm Wax Treatment

This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.