Recordable vs first aid: where OSHA draws the medical treatment line
Short answer
OSHA's first aid list is closed. A work-related injury needing only that care is not recordable on that basis. Anything else, such as prescription medication, sutures, rigid immobilization or most vaccines, is medical treatment and makes a new work-related case recordable. What was done matters, not who did it.
- Rule
- 29 CFR 1904.7(b)(5), medical treatment beyond first aid
- First aid list
- 14 items (A to N), stated to be a complete list
- Provider
- Who gives the treatment does not matter
- Not treatment
- Observation or counseling visits, diagnostic procedures, first aid
- Significant diagnoses
- Cancer, chronic irreversible disease, fractured or cracked bone, punctured eardrum; recordable at diagnosis
- Prescription strength
- More than the single dose on the over-the-counter label (FAQ 7-8)
Applies to: Employers required to keep OSHA injury and illness records · Occupational health nurses, EHS managers and HR staff who decide recordability · Sites with an on-site clinic or first aid room
How does OSHA tell first aid from medical treatment?
OSHA uses a closed list of 14 first aid treatments (1904.7(b)(5)(ii)), and states that it is complete (1904.7(b)(5)(iii)). Medical treatment is the management and care of a patient to combat disease or disorder. It excludes first aid, visits solely for observation or counseling, and diagnostic procedures.
The treatment decides, not the provider's title. Care on the list is first aid even when a physician gives it. Care beyond the list is medical treatment even when a non-clinician gives it (1904.7(b)(5)(iv)).
What is first aid, and what crosses the line?
Fourteen treatments are first aid. Everything else is medical treatment. The table shows the nearest treatment that crosses the line.
| Category | First aid (not recordable on its own) | Medical treatment (recordable) |
|---|---|---|
| Medication | Non-prescription medication at non-prescription strength | Prescription medication, or a non-prescription drug recommended at prescription strength: more than the single dose on the over-the-counter label (FAQ 7-8) |
| Immunization | Tetanus immunization | Other immunizations, such as hepatitis B or rabies vaccine |
| Wounds | Cleaning, flushing or soaking surface wounds. Bandages, gauze, butterfly bandages, Steri-Strips. | Sutures, staples, surgical glue and other closing devices (FAQ 7-5, 7-26) |
| Support | Non-rigid support (elastic bandages, wraps, non-rigid back belts). Temporary splints, slings, neck collars and back boards while transporting a victim. | Devices with rigid stays or designed to immobilize a body part |
| Therapy | Hot or cold therapy; massage | Physical therapy or chiropractic treatment |
| Heat stress | Drinking fluids | Intravenous fluids (FAQ 7-6) |
| Eyes and splinters | Eye patches. Removing an eye foreign body with only irrigation or a cotton swab. Removing splinters by irrigation, tweezers, cotton swabs or other simple means. | Anything not on the list |
| Nails and blisters | Drilling a nail to relieve pressure. Draining fluid from a blister. Finger guards. | Anything not on the list |
What is not medical treatment either?
Three things are not medical treatment (1904.7(b)(5)(i)). They are visits to a physician or other licensed health care professional solely for observation or counseling, diagnostic procedures, and first aid. Diagnostic procedures include x-rays, blood tests and prescription medication used only for diagnosis, such as pupil-dilating drops.
How do the rules apply to realistic cases?
These scenarios are invented for illustration. Each assumes the case is work-related and new. Real cases turn on the facts and what the clinician did.
| Scenario | Recordable? | Why |
|---|---|---|
| Hand cut cleaned and covered with an adhesive bandage; full duty continues | No | Cleaning and a bandage are first aid. |
| The same cut is closed with Steri-Strips | No | Steri-Strips and butterfly bandages are on the list. |
| The same cut is closed with sutures or surgical glue | Yes | Other closing devices are medical treatment. |
| Sore shoulder: pain reliever from the first aid kit at the label dose | No | Non-prescription medication at non-prescription strength. |
| Same complaint: a clinician prescribes more than the label dose | Yes | Prescription strength is medical treatment. |
| Ankle x-ray shows no fracture; elastic wrap applied | No | A diagnostic procedure plus non-rigid support. |
| Ankle x-ray shows a hairline fracture; no treatment ordered | Yes | A fractured or cracked bone is recordable at diagnosis. |
| Heat illness: drinking water in a cool area, versus intravenous fluids | No, then yes | Only drinking fluids is on the list. |
| Chemical vapor exposure; oxygen given as a precaution; no symptoms | No | Precautionary oxygen with no symptoms is not recordable. With symptoms, it is (FAQ 7-15). |
| Emergency room visit for observation only; released with no treatment | No | Observation is not medical treatment. |
Can a first aid case still be recordable?
Yes, if it meets another criterion. Restricted work counts when a worker cannot do a routine function (one done at least once a week). It also counts when they cannot work the full shift, other than on the day of the injury. Slower work alone is not a restriction (FAQ 7-4). Days away, job transfer and loss of consciousness also count. If a clinician recommends treatment and the worker declines it, record the case anyway (1904.7(b)(5)(v)).
What should the record show?
OSHA gives no form for this decision. Keep what a reviewer would ask for. These are practice suggestions, not rule text.
- What was done, step by step, and by whom.
- Whether any medication was prescription, and how the dose compared with the label.
- Whether a wound closing device or immobilization was used.
- Clinician advice on restrictions, with dates.
- Any diagnosis, especially a fracture, and its date.
- Who made the recordability decision, and when.
See also first aid vs medical treatment and the glossary entries for first aid and OSHA recordable.
How IncidentKit supports this requirement
| What the rule asks for | Where it lives in IncidentKit |
|---|---|
| Decide whether treatment went beyond the first aid list (1904.7(b)(5)) | Lauren asks what treatment was given, by whom, and whether any drug was prescription. It drafts fields marked 'Lauren · draft'. A person decides recordability. |
| Capture clinician restrictions and day counts | Dates, notes and clinician paperwork stay attached to the record. |
| Show how a call was made | The audit trail records who changed a classification and when, with before and after values. |
| Enter the case on the 300 Log in the right column | Capture the outcome facts now. OSHA 300 export from the same record is rolling out. |
| Learn from minor events that never reach the Log | Analytics cluster incidents by location, shift, equipment and cause, first aid cases and near misses included. |
Product parts involved: Lauren, the AI assistant, Incident reporting, Investigations and RCA, Audit trail, Analytics, Compliance packets. Capabilities marked “rolling out” are being released in stages; see the changelog.
Frequently asked questions
Does treatment by a doctor automatically make a case recordable?
No. Care on OSHA's first aid list is first aid whoever gives it, even a physician. Care beyond the list is medical treatment even from a non-clinician. Document what was done, not the provider's credentials.
Is a tetanus shot recordable?
Not by itself. Tetanus immunization is on the first aid list. Other immunizations, such as hepatitis B or rabies vaccine, are medical treatment. The case can still be recordable for another reason, such as sutures or days away.
Is surgical glue first aid?
No. OSHA says surgical glue is a wound closing device. All such devices except butterfly bandages and Steri-Strips are medical treatment, so sutures, staples and glue make a laceration recordable.
Do x-rays make a case recordable?
No. X-rays and other diagnostic procedures are not medical treatment. But an x-ray that shows a work-related fractured or cracked bone makes the case recordable at diagnosis, even with no treatment.
What if the employee refuses recommended treatment?
Record the case anyway, whether or not the worker follows the advice. The same applies to recommended days away and work restrictions. Encourage the worker to follow treatment a physician or other licensed health care professional recommends.
Sources
- eCFR: 29 CFR 1904.7, General recording criteria (current through 2026-10-01)
- OSHA: 29 CFR 1904.7 regulation text
- OSHA: FAQ 7-5, surgical glues
- OSHA: FAQ 7-6, intravenous fluids and heat stress
- OSHA: FAQ 7-8, prescription strength
- OSHA: FAQ 7-15, oxygen given as a precaution
- OSHA: FAQ 7-27, x-rays and diagnostic procedures
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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