Recordable or first aid? Where OSHA draws the line

Step one: is it work-related and new?

Before the outcome question, two gates. An injury or illness is presumed work-related if an event or exposure in the work environment caused or contributed to it, subject to a short list of exceptions like symptoms that merely surface at work or personal tasks outside working hours (1904.5). It must also be a new case rather than the continuation of one already logged (1904.6). Clear both gates, then look at outcomes.

The six outcomes that make a case recordable

• Death. Also triggers a direct report to OSHA within 8 hours (1904.39), separate from the log.
• Days away from work. Even one. Count calendar days including weekends and holidays, starting the day after the injury; you may stop at a 180-day cap (1904.7(b)(3)).
• Restricted work or job transfer. "Restricted" means the worker is kept from any routine function (something they'd normally do at least once a week) or from a full shift (1904.7(b)(4)). Putting a framer on tool-cleanup duty for three days is a restriction, even though they came to work.
• Medical treatment beyond first aid. The big one. See the list below.
• Loss of consciousness. Any blackout, however brief (1904.7(b)(6)).
• A significant diagnosis. Work-related cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum is recorded when diagnosed, even if no treatment or time off follows (1904.7(b)(7)). A hairline fracture the worker shakes off is still a recordable.

The complete first aid list

These 14 treatments, and only these, count as first aid (1904.7(b)(5)(ii)). A case whose care never goes beyond this list is not recordable on treatment grounds:

1. Non-prescription medication at non-prescription strength
2. Tetanus immunizations (other immunizations, like hepatitis B or rabies, are medical treatment)
3. Cleaning, flushing, or soaking a surface wound
4. Wound coverings: bandages, gauze pads, butterfly bandages, Steri-Strips
5. Hot or cold therapy
6. Non-rigid support: elastic bandages, wraps, non-rigid back belts
7. Temporary immobilization (splint, sling, neck collar, backboard) while transporting the person
8. Drilling a fingernail or toenail to relieve pressure, or draining a blister
9. Eye patches
10. Removing foreign bodies from the eye using only irrigation or a cotton swab
11. Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
12. Finger guards
13. Massage (physical therapy and chiropractic treatment are medical treatment)
14. Drinking fluids to relieve heat stress

OSHA states outright that this list is complete (1904.7(b)(5)(iii)). That cuts both ways: sutures aren't first aid no matter how minor the cut, and a fourth ibuprofen tablet at normal strength is still first aid no matter how bad it looked.

The close calls, settled

• X-rays and diagnostic tests don't count as treatment. Visits solely for observation or diagnostic procedures, including x-rays and blood tests, aren't medical treatment (1904.7(b)(5)(i)). A trip to urgent care that produces a negative x-ray and an ice pack stays first aid.
• Prescriptions are treatment. Prescription medication, or a doctor telling the worker to take an over-the-counter med at prescription strength, crosses the line. The exception: prescription meds used solely for diagnosis, like drops to dilate pupils.
• How the wound gets closed decides. Butterfly bandage or Steri-Strips: first aid. Sutures, staples, or surgical glue: medical treatment, recordable.
• Rigid vs soft. An elastic wrap is first aid. A rigid splint or cast worn as treatment is not. The same splint used only to immobilize during the drive to the clinic is fine.
• The ER visit itself isn't the test. What was done there is. Observation and diagnostics alone don't make a case recordable; the treatment, work restrictions, or diagnosis that come out of the visit might.