CoolSystems, Inc. (Game Ready) asked OSHA whether the cold-therapy-only setting on its therapeutic device is first aid under 29 CFR Part 1904. The device is a dual-modality care system: cold water flows through a hose onto one side of a wrap, while air flows to the other side for compression. The components operate independently, allowing 'pressure off' cold therapy without compression.
In its August 9, 2018 response, OSHA determined that 'applying only the cold therapy component of your device (with no compression) is first-aid for injury and illness recordkeeping purposes.' Section 1904.7(b)(5)(ii) requires recording work-related injuries resulting in medical treatment beyond first aid, and the regulation specifically lists 'using hot or cold therapy' as first aid under subparagraph (E). Section 1904.7(b)(5)(iii) establishes that the first aid list is comprehensive.
The critical distinction is that air compression therapy is not included on the first aid list. Because the list is exhaustive, OSHA concluded that 'when the air compression component of your device is used, either with or without cold therapy, to treat a work-related injury or illness, the case must be recorded on the OSHA 300 log.'