Is It Recordable?
Scenario Q42

Kinesiology Tape: is it recordable?

Verdict: Not recordable
Published 2020-04-19

Question

Upon elbow pain setting in at work, a vehicle seat assembler reports the pain to her supervisor. In the First Aid Office, the site Injury Prevention Specialist (Certified Athletic Trainer) evaluates the employee and puts her on a conservative treatment regimen of over the counter strength Naproxen per directions and cold compress treatments twice per day for three weeks. The icing treatments take place during one 45 minute job rotation per treatment. In addition, the Injury Prevention Specialist applies kinesiology tape to the employee’s elbow on a daily basis. The employee continues her routine job functions at full duty, accomplishing all tasks in her job description more than once per week while her condition is monitored. Is it recordable?

Answer

NO. The Naproxen is over the counter strength and the cold compress treatment is considered First Aid treatment. In July 2015, OSHA reversed their view of kinesiology tape as medical treatment beyond first aid. Finally, the employee is performing all routine job functions at least once per week and did not miss any days away from work.
How do I decide if the injury or illness resulted in restricted work? Restricted work occurs when, as the result of a work-related injury or illness:
1904.7(b)(4)(i)(A)
You keep the employee from performing one or more of the routine functions of his or her job, or from working the full workday that he or she would otherwise have been scheduled to work; or
1904.7(b)(4)(i)(B)
A physician or other licensed health care professional recommends that the employee not perform one or more of the routine functions of his or her job, or not work the full workday that he or she would otherwise have been scheduled to work.
1904.7(b)(4)(ii)
What is meant by "routine functions"? For recordkeeping purposes, an employee's routine functions are those work activities the employee regularly performs at least once per week.
1904.7(b)(5)(ii)
What is "first aid"? For the purposes of Part 1904, \"first aid\" means the following:
1904.7(b)(5)(ii)(A)
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
1904.7(b)(5)(ii)(E)
Using hot or cold therapy;
1904.7(b)(5)(ii)(F)
Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
July 6, 2015 Kinesiology Tape Interpretation Letter: https://www.osha.gov/laws-regs/standardinterpretations/2015-07-06

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(4)(i)(A)

https://www.osha.gov/laws-regs/interlinking/standards/1904.7(b)(5)(ii)

https://www.osha.gov/laws-regs/standardinterpretations/2015-07-06

Illustration for the scenario: Kinesiology Tape

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This is guidance based on 29 CFR Part 1904 and OSHA letters of interpretation. Facts and details may be altered or fictional. As specified by OSHA, the employer is responsible for the final recordability determination.