Most employers with more than 10 employees are required to keep a record of serious work-related injuries and illnesses. However, minor injuries requiring only “first aid” generally do not need to be recorded. OSHA’s definition of “first aid” is a complete listing of all treatments considered first aid. See https://www.osha.gov/recordkeeping/

In a recent standard interpretation, OSHA concluded that soft tissue management (massage) is first aid for recordkeeping purposes. OSHA noted that the recordkeeping regulation does not include special rules for recording soft issue injuries and illnesses and thus the determination of whether to record such injuries is the same analysis as any other injury or illness, i.e., injuries and illnesses involving muscles, nerves, ligaments, joints, cartilage, and spinal discs would meet the general recording criteria if they involve medical treatment beyond first aid, days away from work, job transfer or restricted work.

Finally, OSHA added that the recordkeeping regulation provides that the professional status of the person providing the treatment does not have any effect on what is considered first aid or medical treatment. In other words, the treatments identified as first aid would not change because they were provided by a physician or other licensed health care professional. Accordingly, soft tissue massage is first aid even if administered by individuals with Active Release Techniques (ART) certification.