The National Athletic Trainers' Association asked OSHA to reevaluate its classification of cold compression therapy as medical treatment rather than first aid for recordkeeping under 29 CFR Part 1904. OSHA maintained its position, splitting the analysis by device component.
The cold-only component qualifies as first aid: the regulation explicitly lists 'cold therapy' in 29 CFR 1904.7(b)(5)(ii)(E), so using only the cold therapy component of the device to treat a work-related injury or illness is first aid. But air compression therapy does not appear anywhere on the first-aid list in 1904.7(b)(5)(ii). OSHA concluded that the use of air compression to treat a work-related injury or illness is physical therapy, and therefore medical treatment beyond first aid — which makes the case recordable.
OSHA's reasoning rests on its definition of medical treatment — the management and care of a patient for the purpose of combating disease or disorder, based on Dorland's Illustrated Medical Dictionary — and on the principle that the first-aid list in 1904.7(b)(5)(ii) is comprehensive: treatments not on the list are not first aid.
One useful exception: cold compression therapy applied preventatively to asymptomatic employees is not recordable, including when it is part of a wellness program.