Is a first aid visit OSHA recordable?

No. If the only treatment given was first aid, the case is not recordable — even if a licensed medical professional gave it. But OSHA defines first aid as a specific, closed list of fourteen treatments. Anything not on that list counts as medical treatment, and medical treatment makes the case recordable.

Source: 29 CFR 1904.7(b)(5)(ii) — read it on osha.gov

What OSHA counts as first aid

The complete list from 1904.7(b)(5)(ii):

  1. Using non-prescription medication at non-prescription strength
  2. Cleaning, flushing or soaking surface wounds
  3. Using wound coverings (bandages, gauze, etc.)
  4. Using hot or cold therapy
  5. Using non-rigid supports (elastic bandages, wraps, etc.)
  6. Using temporary immobilization devices during transport (splints, slings, etc.)
  7. Drilling a fingernail or toenail to relieve pressure
  8. Draining fluid from a blister
  9. Using eye patches
  10. Removing foreign bodies from the eye using irrigation or cotton swab
  11. Removing splinters or foreign material by irrigation, tweezers, cotton swab, or other simple means
  12. Using finger guards
  13. Using massages
  14. Drinking fluids to relieve heat stress

If the treatment given is on this list, it's first aid. If it's not on the list, it's medical treatment — and the case is recordable.

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 enough.

Wound closure

Butterfly bandages and Steri-Strips are first aid. Sutures, staples, and tissue adhesives are medical treatment.

Days away or restricted duty

The treatment test and the days-away test are separate. First aid treatment plus one day away from work is still a recordable case under 1904.7(b)(3).

Loss of consciousness

Recordable on its own, regardless of treatment, under 1904.7(b)(4).

What you still have to do for a case that isn't recordable

Record it somewhere. OSHA does not require first aid cases to go on the 300 log, but most employers keep a separate first aid log for three reasons. First, tracking near-misses and minor injuries identifies hazards before they cause a recordable. Second, if a case worsens — the employee sees their own doctor and gets a prescription, or loses a day of work later — it becomes recordable from the date of the original injury. A first aid log gives you the date. Third, state workers' compensation often requires an injury report even when OSHA does not.

Why recording a borderline case is the safer mistake

Over-recording is not penalized. If you record something that later turns out not to be recordable, you correct it. Under-recording — failing to record a case that should have been on the log — is a citation.

When a case is genuinely unclear, the regulation allows for judgment. But when in doubt, recording it and correcting it later is a better position than explaining why you didn't record it at all.

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