First Aid vs Medical Treatment: What Must You Record?

A worker gets a cut at 10 a.m. They get a bandage, go back to work, and everyone moves on. Another worker gets the same cut, but a clinic closes it with stitches. One of these goes on your OSHA 300 Log and one doesn’t. The difference is whether the treatment counts as first aid or medical treatment, and getting it wrong is one of the most common recordkeeping errors.

The basic rule

A work-related injury or illness is recordable if it is a new case and it results in death, days away from work, restricted work or job transfer, loss of consciousness, medical treatment beyond first aid, or a significant injury or illness diagnosed by a physician or other licensed health care professional. So the first question is simple: was the treatment more than first aid?

OSHA treats the list of first aid treatments as complete. If a treatment is not on the list, it counts as medical treatment. And it’s the treatment that matters, not who gives it. First aid given by a doctor is still first aid.

What counts as first aid

According to OSHA’s recordkeeping rules, these are the treatments considered first aid:

  • Non-prescription medication at non-prescription strength
  • Tetanus immunizations
  • Cleaning, flushing or soaking wounds on the skin surface
  • Wound coverings such as bandages, gauze pads, butterfly bandages or Steri-Strips (but not sutures)
  • Hot or cold therapy
  • Non-rigid supports such as elastic bandages and wraps, and non-rigid back belts
  • Temporary immobilization devices only while transporting an injured person
  • 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 other areas by irrigation, tweezers, cotton swab or other simple means
  • Finger guards
  • Massages (physical therapy and chiropractic treatment are not first aid)
  • Drinking fluids to relieve heat stress

What counts as medical treatment

Anything beyond that list is generally medical treatment. Common examples:

  • Stitches or staples to close a wound
  • Prescription medication, or non-prescription medication at prescription strength
  • Physical therapy or chiropractic treatment
  • Immunizations other than tetanus (for example, rabies or hepatitis B)
  • Rigid splints, casts or other devices designed to immobilize a body part
  • Other treatment to manage and care for the patient that is not on the first aid list

A visit to a health care professional solely for observation or counseling, or diagnostic tests such as x-rays and blood tests, is not medical treatment on its own. But if the provider then prescribes medication or gives other treatment, the case may become recordable.

Quick examples

Situation Recordable? Why
Cut cleaned and covered with a bandage No (if nothing else applies) Cleaning and bandaging are first aid
Cut closed with stitches Yes Sutures are medical treatment
Employee takes over-the-counter pain relievers at label strength No (if nothing else applies) Non-prescription medication at non-prescription strength is first aid
Doctor prescribes a stronger pain medication Yes Prescription medication is medical treatment
X-ray shows no fracture; ice pack and elastic wrap No (if nothing else applies) Diagnostics, hot/cold therapy and non-rigid support are not medical treatment
Wrist in a rigid splint, with restricted duty Yes Rigid immobilization is medical treatment, and the restriction may also make it recordable

 

Don’t forget the other criteria

A case treated with only first aid can still be recordable if it also involves days away from work, restricted work or a job transfer, loss of consciousness, or a significant diagnosed injury. Check every criterion, not just the treatment.

Practical tips

  • Ask exactly what treatment was given. “They went to the clinic” isn’t enough to decide.
  • Get the provider’s treatment notes or discharge papers for your file.
  • Decide using the rules, not what looks good on your injury rate. Over-recording and under-recording both create risk.
  • Document your reasoning on borderline cases so you can explain it in an inspection.
Join the webinar

Borderline cases are where recordkeeping gets hard. Our webinar covers the first aid and medical treatment rules with practical examples, so your team can decide with confidence. Register for “OSHA 300 Logs: Reporting & Recordkeeping Requirements for 2026”.

Related reading: OSHA 300 vs 300A vs 301 • 10 Common OSHA 300 Log Mistakes.

This article is general information, not legal advice. OSHA updates its rules and industry lists from time to time, so confirm current requirements at osha.gov before you act.

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