An occupational health provider asked OSHA whether Clozex and ZipStitch — over-the-counter, noninvasive wound closure devices that require no specialized training — count as first aid when used on minor lacerations. Clozex is marketed as a surgical skin closure, and ZipStitch is marketed for home use with surgical quality.
In its October 9, 2019 letter, OSHA determined that both devices constitute medical treatment, not first aid. The regulation at 29 CFR 1904.7(b)(5)(ii)(D) lists as first aid 'wound coverings such as bandages, Band-Aids, gauze pads, etc.; or using butterfly bandages or Steri-Strips' — and explicitly notes that 'other wound closing devices such as sutures, stitches, etc. are considered medical treatment.'
The critical point is that OSHA's first aid list is comprehensive and exhaustive. Among wound closure devices, only Steri-Strips and butterfly bandages qualify as first aid. Because ZipStitch and Clozex are wound closing devices not explicitly listed, they are medical treatment, and a work-related laceration treated with them must be recorded. OSHA noted this distinction traces to the 2001 rulemaking, which drew the line based on training requirements and wound severity — the devices' over-the-counter availability did not change the outcome.