The section specifically states that the use of massage is first aid. Section 1904, 7 (b) ((iii) states that the list of first aid treatments in section 1904, 7 (b) ((ii) is a complete list of first aid treatments. Under federal OSHA definitions, massage and exercise guidelines are listed as first-aid injury prevention measures. However, when a provider prescribes specific therapeutic exercises in response to a work-related injury or illness, it is medical treatment and becomes an OSHA record.
In a recent standard interpretation, OSHA concluded that soft tissue management (massage) is first aid for record-keeping purposes. OSHA noted that the record-keeping regulations do not include special rules for recording injuries and soft tissue diseases and, therefore, the determination of whether to record such injuries is the same analysis as any other injury or illness, that is, for OSHA registration purposes, “first aid includes the following items. This is a complete list of all the treatments that OSHA considers first aid.