OSHA Reverses Position on Kinesiology Tape as Medical Treatment

Article brought to you by: Stephen A. Burt, BS, MFA

In an interpretation letter to the National Athletic Trainers’ Association dated July 6, 2015, OSHA reversed its earlier interpretation that the use of kinesiology tape is considered medical treatment for recordkeeping purposes. Late 2014, OSHA issued an interpretation letter which stated that the use of kinesiology tape is considered medical treatment for OSHA recordkeeping purposes and is, therefore, recordable when used to treat a work-related injury.

At the request of the National Athletic Trainers’ Association, OSHA has reevaluated its classification of the application of kinesiology tape as constituting medical treatment. Kinesiology tape is a thin, stretchy, elastic cotton strip with an acrylic adhesive. It is almost identical to human skin in both thickness and elasticity, which allows it to be worn without binding or restricting movement. The tape is used to treat a variety of musculoskeletal and sports injuries, and inflammatory conditions. OSHA reviewed information associated with such tape from patent applications, from relevant instructional materials and directions for when and how to use it, from evaluations and descriptive experiences involving recommended uses and their efficacy, from assessments regarding the nature and mechanisms of its effects, and from reviews of the extent and nature of any medicinal, neurological, and physical properties and impacts.

Pursuant to 29 CFR 1904.7, first aid treatment includes “any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.” The distinction is significant because under OSHA’s injury and illness reporting and record-keeping rules, any injury that requires medical treatment beyond first aid is a recordable injury. OSHA’s latest interpretation recognizes that using the tape alone falls inside the scope of its definition for first aid.
The July 6, 2015 letter of interpretation may be found at: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=29516