A nurse practitioner asked OSHA whether applying heated paraffin wax as a topical heat treatment is medical care beyond first aid under the recordkeeping rules in 29 CFR Part 1904. This matters because a work-related injury treated only with first aid does not have to go on the OSHA 300 log, while one that receives medical treatment beyond first aid does (1904.7(a)).
In its October 22, 2024 letter, OSHA determined that heated paraffin wax qualifies as 'hot or cold therapy' under 1904.7(b)(5)(ii)(E), which states that 'the use of hot and cold therapy to treat a work-related injury or illness is first aid.' Paraffin wax works by increasing blood flow and reducing stiffness through thermal application, so it fits the definition. When paraffin wax is used alone, the injury is not recordable — regardless of how frequently it is applied, where it is applied, or the type of injury.
The key exception: if paraffin wax is used alongside other interventions that meet recordability criteria — such as physical therapy, exercise programs, or prescription medication — the case becomes recordable. OSHA noted that significant injuries typically involve 'some other form of medical treatment (such as prescription drugs, physical therapy, or chiropractic treatment), restricted work, or days away from work.'