When minor worker injuries occur on the job, first aid is typically rendered. However, under OSHA regulations, there is a fine line between what is considered first aid and what OSHA labels medical treatment. Knowing exactly where that line is matters to employers in terms of staying in compliance with OSHA workplace regulations, most specifically the agency's recordkeeping regulation contained in 29 CFR 1904, "Recording and Reporting Occupational Injuries and Illnesses."
In December 2014 OSHA declared that use of Kinesiology tape in treating workplace injuries was considered a medical treatment for OSHA recordkeeping purposes, rather than first aid. If you are among the many employers who banished this tape from first aid kits, you should know that OSHA has reversed that interpretation and has now approved it as first aid.
In a July 2015 letter of interpretation to Mr. Jim Thornton of the National Athletic Trainers' Association, OSHA stated that it had, as requested, reevaluated its classification of the application of Kinesiology tape as constituting medical treatment. The agency said it had reviewed information associated with the tape from sources that included:
- Patent applications
- Relevant instructional materials and directions for when and how to use the tape
- Evaluations and descriptive experiences involving recommended kinesiology tape uses and their efficacy
- Assessments regarding the nature and mechanisms of its effects
- Reviews of the extent and nature of any medicinal, neurological, and physical properties and impacts of it
As a result of that review, OSHA concluded that the use of kinesiology tape and other types of elastic taping is included within first aid treatment as defined by the agency: "first aid treatment includes any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc." Since it was determined to fall under the category of first aid, use of such tape alone in treating workplace injuries would no longer be considered medical treatment under OSHA record keeping regulations.
What that means to employers is that it is safe to put Kinesiology tape back into workplace first aid kits. With the issue of this new letter of interpretation, using kinesiology tape in treating workplace injuries no longer creates a situation in which a minor first aid incident becomes a reportable workplace injury based solely upon its use.