First aid vs medical treatment: where OSHA draws the recordability line
Short answer
A work injury is recordable if it needs medical treatment beyond first aid (29 CFR 1904.7). OSHA's first-aid list is closed, with 14 treatments. Anything else, such as stitches, prescription medication or a rigid splint, is medical treatment. Who gives the care does not matter.
The line is a closed list of 14 treatments
If every treatment given is on OSHA's first-aid list in 29 CFR 1904.7(b)(5)(ii), it is first aid. If any treatment is not on the list, it is medical treatment, and the case is recordable on the OSHA 300 Log. OSHA calls the list complete.
The rule defines medical treatment as managing and caring for a patient to combat disease or disorder.
Three things are not medical treatment: visits solely for observation or counseling; diagnostic procedures such as x-rays and blood tests, including prescription drugs used only for diagnosis, like eye drops to dilate pupils; and first aid.
Who gives the care does not change the answer. A listed treatment given by a physician is still first aid. A treatment beyond the list given by someone unlicensed is still medical treatment. See first aid and OSHA recordable.
What is on the first-aid list
The rule lists 14 treatments, labeled A through N. The table groups them and shows what tips each group into medical treatment.
| Area | First aid | Medical treatment instead |
|---|---|---|
| Medication | Non-prescription medication at non-prescription strength | Any prescription medication, or non-prescription medication at prescription strength recommended by a licensed professional |
| Immunizations | Tetanus | Other vaccines, such as hepatitis B or rabies |
| Wounds | Cleaning, flushing or soaking surface wounds; bandages, gauze, butterfly bandages or Steri-Strips | Sutures, staples or other wound-closing devices |
| Therapy | Hot or cold therapy; massage | Physical therapy or chiropractic treatment |
| Support | Non-rigid support such as elastic bandages, wraps or non-rigid back belts; temporary splints, slings or collars while transporting a victim | Devices with rigid stays or other systems that immobilize body parts |
| Eyes | Eye patches; removing a foreign body using only irrigation or a cotton swab | Other methods of removal |
| Other | Draining a blister or drilling a nail to relieve pressure; removing splinters by irrigation, tweezers or swab; finger guards; drinking fluids for heat stress | Anything not on the list, such as IV fluids |
Most calls turn on one detail
What was done, with what, at what strength? These examples are illustrative. Each assumes nothing else triggers recording.
| Case | Recordable? | Why |
|---|---|---|
| An aide cuts a finger. The wound is cleaned and covered with an adhesive bandage. | No | Cleaning and bandages are first aid. |
| The same cut is closed with three sutures. | Yes | Sutures are medical treatment. |
| A back strain gets an ice pack and over-the-counter ibuprofen at label strength. | No | Cold therapy and non-prescription medication are first aid. |
| The same strain, but a clinician prescribes prescription-strength ibuprofen. | Yes | Prescription strength is medical treatment. |
| A fall on an outstretched hand. The x-ray is negative. An elastic wrap is applied. Full duty. | No | X-rays are diagnostic. A non-rigid wrap is first aid. |
| The same fall, but the x-ray shows a hairline fracture. | Yes | A fractured or cracked bone is recordable at diagnosis. |
| A housekeeper gets a tetanus shot after a scratch from a rusty cart. | No | Tetanus immunization is first aid. Hepatitis B or rabies vaccine would not be. |
| Heat illness is treated with IV fluids at urgent care. | Yes | Drinking fluids is first aid. IV fluids are not on the list. |
A first-aid-only case can still be recordable
First aid is one test of several. A work-related injury or illness is also recordable if it causes death, days away from work, restricted work or job transfer, loss of consciousness, or a significant diagnosis.
That means cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.
- Days away: count calendar days from the day after injury, weekends included. Stop at 180.
- Restricted work: a routine function (done weekly) or full shift is off limits.
- Vague notes: for "light duty," ask if all routine functions are possible.
- Refused care: still recordable if the employee declines advised treatment.
Healthcare adds needlestick rules and exemptions
Under 29 CFR 1904.8, record every work-related needlestick or cut from a sharp contaminated with another person's blood or other infectious material, as an injury, with no employee name on the 300 Log.
A splash with no cut is recordable only if it leads to a bloodborne illness diagnosis or meets the general criteria.
Not every employer keeps the log. Employers with 10 or fewer employees are partially exempt, and so are establishments in industries listed in Appendix A to Subpart B of Part 1904.
That list includes NAICS 6214 (outpatient care centers), offices of physicians, dentists and other health practitioners, and medical and diagnostic laboratories. Hospitals and nursing care facilities are not on it. Check your NAICS code and state plan.
Partial exemption does not remove the duty to call OSHA. Report a work-related death within 8 hours. Report an in-patient hospitalization, amputation or loss of an eye within 24 hours. See severe injury reporting.
Document the call so it holds up
Most disputed calls come down to a missing detail, such as whether a medication was prescription. Write down:
- Each treatment given, by whom, and when.
- The medication name, strength, and whether it was prescription.
- The provider's work-status note, with restrictions and dates.
- Days away and days restricted, and how you counted.
- Your reasoning for the call.
Enter the case on the 300 Log and complete Form 301 or an equivalent within 7 calendar days of learning of it. Keep the Log and forms 5 years after the year they cover.
Give an employee a copy of their 301 by the end of the next business day if they ask.
IncidentKit collects the facts; a person makes the call
Lauren asks follow-ups such as whether a medication was prescribed, whether a provider restricted duties and how many days were missed. It fills the form for review. A person decides.
OSHA 300, 300A and 301 exports are rolling out. Today the value is complete facts and an audit trail of who decided what. See workplace injury reporting, OSHA 300 log automation, recordable vs first aid and the OSHA recordkeeping guide.
Frequently asked questions
Is an adhesive bandage recordable?
No. Wound coverings such as bandages, gauze pads, butterfly bandages or Steri-Strips are first aid under 29 CFR 1904.7. The case is recordable only if something else triggers recording, such as days away, restricted work, loss of consciousness, a significant diagnosis or other medical treatment.
If a doctor gives first-aid treatment, is the case recordable?
No. OSHA says the provider's professional status has no effect. A listed treatment stays first aid even when a physician gives it. Treatment beyond the list is medical treatment even when an unlicensed person gives it. What was done decides the call.
Are x-rays and blood tests medical treatment?
No. Diagnostic procedures are not medical treatment, including prescription drugs used only for diagnosis, such as eye drops to dilate pupils. If the x-ray shows a fractured or cracked bone, the case is recordable at diagnosis, even with no treatment.
What if the employee refuses the recommended treatment?
Record the case anyway. If a licensed professional recommends medical treatment, encourage the employee to follow it, but the case is recordable even if they do not. The same applies to recommended days away: record the days recommended.
Does a tetanus shot make an injury recordable?
Not by itself. Tetanus immunization is first aid. Other vaccines, such as hepatitis B or rabies, are medical treatment. If the injury was a needlestick or cut from a sharp contaminated with blood or other infectious material, record it anyway under 29 CFR 1904.8.
Sources
- 29 CFR 1904.7: General recording criteria
- 29 CFR 1904.8: Recording criteria for needlestick and sharps injuries
- 29 CFR 1904.39: Reporting fatalities, hospitalizations, amputations and losses of an eye
- 29 CFR Part 1904 Subpart B: Scope, including Appendix A partially exempt industries
- 29 CFR 1904.29 and 1904.35: Forms and employee involvement
- OSHA forms for recording work-related injuries and illnesses (Forms 300, 300A and 301)
Reviewed against the sources above on Oct 5, 2026. Rules change: confirm current requirements with the issuing body or your counsel before relying on any summary.
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