Recordable or First Aid? Where OSHA Draws the Line

An employee gets hurt at work and someone treats the injury. Whether that case belongs on your OSHA 300 Log often comes down to one question: was the treatment first aid, or was it medical treatment beyond first aid? OSHA's recordkeeping rule answers that with a definition and a closed list.

Treatment is only one of the recording criteria

If you are required to keep OSHA injury and illness records, you must record each fatality, injury, and illness that is work-related, is a new case, and meets one or more of the general recording criteria of 1904.7 or the specific-case rules of 1904.8 through 1904.12 (1904.4(a)).

You must consider an injury or illness recordable if it results in any of these: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness (1904.7(a)). A case also meets the criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if none of those outcomes occurs (1904.7(a)).

So "it was only first aid" does not end the analysis. A case still meets the general recording criteria if it involves days away from work (1904.7(b)(3)), restricted work or job transfer (1904.7(b)(4)), or loss of consciousness, regardless of how long the employee remains unconscious (1904.7(b)(6)). Work-related cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded at the time of diagnosis by a physician or other licensed health care professional (1904.7(b)(7)).

What does OSHA mean by medical treatment?

If a work-related injury or illness results in medical treatment beyond first aid, you must record it on the OSHA 300 Log (1904.7(b)(5)).

Medical treatment means "the management and care of a patient to combat disease or disorder" (1904.7(b)(5)(i)). For Part 1904, it does not include:

Visits to a physician or other licensed health care professional solely for observation or counseling (1904.7(b)(5)(i)(A))
Diagnostic procedures, such as x-rays and blood tests, including prescription medications used solely for diagnostic purposes, such as eye drops to dilate pupils (1904.7(b)(5)(i)(B))
First aid as defined in the rule (1904.7(b)(5)(i)(C))

The first aid list has 14 items

For Part 1904, "first aid" means the following (1904.7(b)(5)(ii)):

Using a non-prescription medication at nonprescription strength
Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment)
Cleaning, flushing or soaking wounds on the surface of the skin
Using wound coverings such as bandages, Band-Aids™, gauze pads, etc., or using butterfly bandages or Steri-Strips™
Using hot or cold therapy
Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.
Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)
Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
Using eye patches
Removing foreign bodies from the eye using only irrigation or a cotton swab
Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
Using finger guards
Using massages
Drinking fluids for relief of heat stress

Items 1, 4, 6, and 13 each carry a limit written into the rule itself. Those limits are covered below.

The list is complete, and who gives the care does not matter

The rule says this is a complete list of all treatments considered first aid for Part 1904 purposes (1904.7(b)(5)(iii)).

The listed treatments are first aid even when a physician or other licensed health care professional provides them, and treatment beyond first aid is medical treatment even when someone other than a physician or other licensed health care professional provides it (1904.7(b)(5)(iv)).

If a physician or other licensed health care professional recommends medical treatment, you should encourage the employee to follow it, but you must record the case even if the employee does not (1904.7(b)(5)(v)).

Four limits written into the list

Medication strength. A non-prescription medication at nonprescription strength is first aid. 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 (1904.7(b)(5)(ii)(A)).
Closing a wound. Bandages, gauze pads, butterfly bandages, and Steri-Strips™ are first aid. Other wound closing devices such as sutures and staples are considered medical treatment (1904.7(b)(5)(ii)(D)).
Rigid versus non-rigid support. Elastic bandages, wraps, and non-rigid back belts are first aid. Devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment (1904.7(b)(5)(ii)(F)). Temporary immobilization devices used while transporting an accident victim are a separate first aid item (1904.7(b)(5)(ii)(G)).
Therapy. Massages are first aid. Physical therapy or chiropractic treatment are considered medical treatment (1904.7(b)(5)(ii)(M)).

How to work a case

Confirm the case is work-related and a new case (1904.4(a)).
Check the other criteria in 1904.7(a) before you look at treatment.
Set aside visits solely for observation or counseling and diagnostic procedures (1904.7(b)(5)(i)).
Compare each remaining treatment to the 14 items. If it is not on the list, it is not first aid (1904.7(b)(5)(iii)), whoever provided it (1904.7(b)(5)(iv)).
If a physician or other licensed health care professional recommended medical treatment and the employee did not follow it, record the case (1904.7(b)(5)(v)).

Source

This article relies on the regulation text of 29 CFR 1904.7 and 29 CFR 1904.4 on osha.gov. The regulation itself always controls. States that run their own OSHA-approved State Plans must have the same requirements as Federal OSHA for determining which injuries and illnesses are recordable and how they are recorded (29 CFR 1904.37(b)(1)). For other Part 1904 provisions, State Plan requirements may be more stringent than or supplemental to the Federal requirements (1904.37(b)(2)).