First aid vs medical treatment
This is the single distinction that decides most recordability calls. 29 CFR 1904.7(b)(5) defines first aid with a closed list — if the treatment is on that list and nothing else happened, the case stays off the 300 log. Anything beyond it is medical treatment, and the case is recordable.
The first-aid list (1904.7(b)(5)(ii))
First aid means any one-time, non-prescription treatment of a minor injury, using only the following:
| First aid — not recordable on its own |
|---|
- Non-prescription medication at non-prescription strength
- Administering tetanus immunisations
- Cleaning, flushing or soaking surfaces of wounds
- Using butterfly bandages or Steri-Strips
- Using hot or cold therapy
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts
- Using temporary immobilisation devices while transporting an accident victim
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Using 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
- Using finger guards
- Using massages
- Drinking fluids for relief of heat stress
|
What counts as medical treatment
| Medical treatment — recordable | Why |
|---|
| Prescription medication (including a prescription-strength dose of an OTC drug) | Outside the first-aid list |
| Stitches, staples, surgical glue or other wound closure | Outside the list, even for a small cut |
| Casting or rigid splinting, surgery, physical therapy, chiropractic adjustment, breathing treatments, IV fluids | Outside the list |
| Any treatment a physician or other licensed health care professional directs beyond the first-aid list | 1904.7(b)(5)(i) |
What is explicitly not medical treatment
1904.7(b)(5)(i) carves out three things that feel like treatment but are not:
- Observation or counselling only — a visit solely to observe or counsel is not medical treatment.
- Diagnostic procedures — x-rays, blood tests and similar diagnostics, including prescription medication given during a diagnostic procedure.
- First aid as defined above, even if a physician performs it at a clinic.
Five traps that turn a minor case into a recordable one
- "They went to the doctor" is not the test. A clinic visit that ends with a bandage and an ice pack is first aid; the visit itself is not medical treatment.
- Stitches are medical treatment, even one stitch, even in an urgent care, even if the person returns to work immediately.
- A prescription is medical treatment — including antibiotics "just in case", and including a prescription-strength dose of something sold OTC.
- Rigid support counts. A sling, a walking boot or a rigid splint is medical treatment; an elastic wrap or a non-rigid back belt is first aid.
- Diagnostics cut the other way. An x-ray on its own does not make the case recordable — but if it finds a fracture, the fracture is a significant injury diagnosed by a physician, so the case is recordable on that basis.
One more: first aid must be a one-time treatment. The same "first-aid" treatment repeated over several days (for example daily soaking) moves out of the list.
Not sure whether the case is recordable? Walk it through the
decision tool — it returns the call, the citation and the privacy flag.