Determining whether an injury requires “first aid” or “medical treatment” is one of the most common challenges in OSHA recordkeeping. Since medical treatment makes a case recordable, understanding the difference is essential. Below is a simple guide based on OSHA’s definitions and real-world scenarios to help build confidence in your reporting process.

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What counts as First Aid?

OSHA identifies 14 specific first-aid treatments, including:

  • Cleaning, flushing, or soaking wounds
  • Using wound coverings such as bandages
  • Removing non-eye splinters or foreign material with simple tools (irrigation, tweezers, cotton swabs)
  • Using non-prescription strength medications
  • Drilling a fingernail or toenail to relieve pressure
  • One-time use of physical therapy or massage limited to evaluation

These treatments do not make an injury recordable by themselves.
For the entire list of OSHA’s First Aid Treatments, click here.

FYI: OSHA’s first-aid list is intentionally narrow. If it isn’t on the list, OSHA likely considers it medical treatment.

What counts as Medical Treatment?

Medical treatment includes procedures beyond the defined first-aid list, such as:

  • Sutures, staples, or medical glue to close wounds
  • Prescription medications
  • Orthopedic devices beyond simple splints
  • Multiple physical therapy appointments
  • Treatment for fractures, cracked bones, punctured eardrums
  • Medical imaging used in the course of treatment (diagnostic imaging alone does not automatically make a case recordable)

Many employers overlook OSHA’s requirement to record significant diagnoses such as fractures—even when no additional treatment occurs.

Clarifying the Difference

Scenario One: A laceration closed with sutures or medical glue

An employee sustains a cut that requires sutures or medical glue to close the wound.

Many employers assume wound care of any kind is first aid, but once a wound is closed using sutures, staples, or glue, it crosses firmly into medical treatment.

Recordable. This exceeds first aid.

Scenario Twp: An MRI ordered after a shoulder injury

An employee undergoes an MRI after reporting shoulder pain.

Diagnostic procedures often get mistaken as medical treatment, but OSHA is clear: imaging alone does not make a case recordable.

Not automatically recordable. Unless the results lead to medical treatment beyond first aid or one of OSHA’s other criteria.

A Surprising Example: Drilling a fingernail to relieve pressure

Though it seems like an advanced procedure, OSHA lists this as first aid.

It demonstrates OSHA’s commitment to a very narrow, defined list of first-aid activities.

First aid. Not recordable unless other criteria are triggered.

Why getting it right matters

Misclassifying medical treatment is one of the most common OSHA log errors—often leading to over-reporting that distorts injury trends and complicates claims data. Understanding these distinctions ensures compliance, supports accurate safety benchmarking, and strengthens your overall risk management strategy.

Yes/And: Our Take

Yes, OSHA’s recordkeeping rules can be confusing, and that’s exactly why M3’s dedicated Risk Management team walks clients through these distinctions every day. From reviewing individual cases to auditing full-year logs before posting deadlines, we help you maintain accuracy, reduce exposure, and build confidence in your reporting process.

If you’re unsure whether a case should be logged, your M3 Risk Manager can walk through the criteria with you—case by case.