Answer Library / Recordkeeping OSHA letter · 2019-10-09

Are ZipStitch or Clozex wound closure devices first aid or medical treatment under OSHA?

Quick answer

OSHA classified both ZipStitch and Clozex as medical treatment beyond first aid, making cases treated with them recordable (29 CFR 1904.7(b)(5)(ii)(D)). Among wound closure devices, only butterfly bandages and Steri-Strips count as first aid — and the first aid list is exhaustive.

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.

29 CFR 1904.7(b)(5)(ii)(D)
Source: OSHA Standard Interpretation letter, 2019-10-09 — read the official letter on osha.gov →
Interpretation letters explain how OSHA applies its rules to specific situations. Always verify current requirements — regulations and enforcement policies change.

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