Medical Treatment Beyond First Aid: OSHA Recordability Examples
Medical treatment is any treatment not on OSHA's 14-item first aid list, such as prescription medication, sutures, rigid splints, or physical therapy.
The answer up front
Medical treatment is any treatment not on OSHA's 14-item first aid list, such as prescription medication, sutures, rigid splints, or physical therapy. It excludes observation visits and diagnostic tests, and it counts whether a doctor, a nurse, or a coworker provides it.
The phrase sounds clinical, but the OSHA question is more specific than whether a doctor was involved.
The rule in plain English
A case goes on the OSHA 300 Log when three things are true: it is work-related (29 CFR 1904.5), it is a new case (29 CFR 1904.6), and it meets at least one general recording criterion (29 CFR 1904.7). The criteria are death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional (cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum). Special rules add needlesticks, medical removal, hearing loss, and tuberculosis (29 CFR 1904.8 to 1904.11).
OSHA's complete first aid list
These 14 treatments are first aid under 29 CFR 1904.7(b)(5)(ii). Anything else is medical treatment.
- Nonprescription medication at nonprescription strength (a recommendation to use it at prescription strength is medical treatment)
- Tetanus immunizations (other immunizations, such as hepatitis B or rabies vaccine, are medical treatment)
- Cleaning, flushing, or soaking wounds on the surface of the skin
- Wound coverings such as bandages, gauze pads, butterfly bandages, or Steri-Strips (sutures, staples, and other closing devices are medical treatment)
- Hot or cold therapy
- Non-rigid means of support, such as elastic bandages, wraps, or non-rigid back belts (devices with rigid stays are medical treatment)
- Temporary immobilization devices while transporting an accident victim, such as splints, slings, neck collars, or back boards
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- 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
- Finger guards
- Massages (physical therapy and chiropractic treatment are medical treatment)
- Drinking fluids for relief of heat stress
Applying it to real cases
Treatment beyond OSHA's first aid list usually makes a work-related case recordable. Recordability answers change as medical facts arrive, so a case decided on day one without notes is hard to defend in January. The fix is to decide in order (work-relatedness, new case, criteria) and to write down the treatment and work-status facts each decision rests on, including medication strength.
Coordinators tend to do the data entry and chase the facts, so a short list of what to ask for, and from whom, saves more time than any template.
Where teams go wrong
Teams often assume treatment by a physician is always medical treatment for OSHA purposes.
Each recordable case adds to the 300A totals and the TRIR; days-away and restricted cases also count toward DART. For establishments with 100 or more employees in Appendix B industries, each case also becomes a row in the ITA case data.
Situations that change the answer
- OSHA treats listed first aid as first aid regardless of the provider's professional status.
- OSHA's first aid list is complete. A treatment that is not on it is medical treatment for recordkeeping, no matter who provides it.
A worked example
An employee with a bruised hand sees a physician, gets an x-ray (negative), and is told to use ice and over-the-counter ibuprofen at the label dose. A doctor was involved and a test was run, but every treatment is on the first aid list, so the case is not recordable. If the physician had prescribed a stronger anti-inflammatory, it would be.
A checklist you can reuse
- List the treatments given or recommended.
- Remove diagnostic tests and observation visits.
- Compare what remains with the first aid list.
- Record the case if any treatment goes beyond first aid.
What to keep in the case file:
- What the provider recommended, in writing if possible, including medication strength
- Work status notes (full duty, restrictions, or days away) with dates
- The work-relatedness basis and any exception considered
- The date you learned of the case and the date it became recordable
Where 300log helps
300log records each case's outcome, day counts, and case type in the columns the OSHA 300 Log uses, shows OSHA's definitions (such as restricted work) while you classify, and recalculates the 300A whenever a case changes.
For a quick answer without an account, use the free recordability checker.
Frequently asked questions
Is a clinic visit automatically recordable?
No. A visit for observation, counseling, or diagnostic tests is not medical treatment. The case is recordable only if a recording criterion is met, such as treatment beyond first aid or a work restriction.
Is prescription medication always recordable?
A recommendation to use prescription medication, or a nonprescription drug at prescription strength, is medical treatment. The exception is medication used solely for diagnosis, such as eye drops to dilate pupils.
Who decides recordability, the doctor or the employer?
The employer. Providers supply the medical facts and recommendations; the employer applies Part 1904 to those facts and records the case.
What if the facts change after we log the case?
Update the log. If a first-aid case later needs medical treatment, or a recordable case later results in days away, change the entry (29 CFR 1904.33(b)).
Sources
Primary regulation and agency guidance this article relies on.
- [1]29 CFR 1904.7: General recording criteriaOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [2]OSHA first aid enforcement guidance for recordkeepingOccupational Safety and Health Administration · osha.gov(opens in a new tab)
- [3]OSHA detailed guidance for the injury and illness recordkeeping ruleOccupational Safety and Health Administration · osha.gov(opens in a new tab)
Written and reviewed by the 300log Editorial Team. Guidance, not legal advice: confirm edge cases with OSHA or counsel.