The American Physical Therapy Association asked OSHA whether soft tissue massage techniques similar to Active Release Techniques (ART) qualify as first aid under the recordkeeping regulations, and whether the provider's certification status changes the answer.
In its May 23, 2019 letter, OSHA affirmed that 'using massages' is first aid under 29 CFR 1904.7(b)(5)(ii)(M), which explicitly lists massage among first aid treatments. OSHA concluded that 'soft tissue massage is first aid for recordkeeping purposes,' whether administered by certified ART practitioners or other healthcare professionals.
On credentials, the regulation specifies that 'the professional status of the person providing the treatment' does not affect the classification — massage is first aid even when delivered by physicians or licensed providers. OSHA also noted that the first aid list in 1904.7(b)(5)(iii) is comprehensive: treatments not on the list are not first aid. Bottom line for employers: work-related soft tissue injuries require recording only when they involve 'medical treatment beyond first aid, days away from work, job transfer or restricted work.'