Safety Sherpa
What OSHA counts as first aid
This is the part that surprises people: first aid is not a judgment about how minor the injury was. It is a closed list. If the treatment appears on it, the treatment is first aid regardless of who administered it or where. If it does not appear, it is medical treatment.
"For the purposes of Part 1904, 'first aid' means the following: …" — followed by an exhaustive list of fourteen treatments.
- Non-prescription medication at non-prescription strength
- Tetanus immunizations
- Cleaning, flushing or soaking a surface wound
- Bandages, gauze pads, butterfly bandages or Steri-Strips
- Hot or cold therapy
- Non-rigid support — an elastic bandage, a wrap, a non-rigid back belt
- Temporary immobilization used to transport an accident victim
- Drilling a fingernail or toenail to relieve pressure, or draining a blister
- Eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material by irrigation, tweezers, a cotton swab or simple means
- Finger guards
- Massages
- Drinking fluids for relief of heat stress
Verify the list against the current rule text before you rely on it for a specific case — this page cites the section so you can.
The four things that turn a first aid case into a recordable one
A prescription. If a licensed health care professional recommends a prescription medication — or a non-prescription medication at prescription strength — that is medical treatment, even if the employee never takes it. The recommendation is the trigger, not the dose.
Wound closure. Butterfly strips and Steri-Strips are first aid. Sutures, staples and wound-closure adhesives are medical treatment. Same wound, different recordability, decided by what closed it.
Days away or restricted duty. The treatment test is not the only test. A case with nothing but first aid is still recordable if it produced days away from work, restricted duty or a job transfer, under 1904.7(b)(3) and (b)(4).
The other general criteria. Loss of consciousness, and a significant injury or illness diagnosed by a physician or other licensed health care professional, are each independently recordable — no treatment test involved.
What you still have to do for a case that isn't recordable
Not recordable is not the same as nothing happened. The case stays out of the 300 log, but the rest of your obligations do not disappear with it.
- Provide the care, and do not discourage the employee from seeking it. Discouraging reporting or treatment is its own violation, and a far more serious one.
- Keep your own internal record of the incident, including what treatment was given. This is what lets you defend the not-recordable call later.
- Investigate it like any other event. First aid cases are leading indicators — the near-miss that costs a bandage this month is the amputation next year.
- Watch for it becoming recordable later. If the employee returns and gets a prescription, or loses days, the case is recordable from that point and belongs on the log.
Why recording a borderline case is the safer mistake
People agonize over this in the wrong direction. Over-recording carries no penalty. There is no citation for a case on your 300 log that did not strictly need to be there, and OSHA expects logs to be corrected — 1904.33 requires you to keep and update them for five years, which presumes they change.
Under-recording is different. A missing entry looks like concealment even when it was an honest reading of a genuinely unclear case, and it invites scrutiny of every other entry you made. If a case is truly borderline, record it, note the reasoning, and correct the log later if you are shown to be wrong.
The one thing to avoid is a decision with no reasoning attached to it. A year later, nobody remembers why the call was made — which is why the point of a decision tree is the record it leaves, not the answer it gives.
Safety Sherpa is software, not a safety consultancy. This page quotes the cited regulation and links to the source text so you can read it yourself. It is not legal advice and does not replace a qualified person's judgment about a genuinely unclear case — our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make.