An employee cuts a hand on a sheet metal edge and goes to the clinic. Two hours later the supervisor calls: "They just cleaned it up and put some Steri-Strips on it. Is that recordable?"
Every HSE manager gets that call. And the answer usually depends less on how bad the injury looked and more on one thing: what treatment the employee actually received. Get it wrong one way and your OSHA 300 log is understated, which is a citation waiting to happen. Get it wrong the other way and your TRIR goes up for a case that never should have been on the log.
Here's how to make the call the same way every time, using the rule OSHA actually wrote: 29 CFR 1904.7.
Step 1: Is It Work-Related and a New Case?
Before you get to treatment, two questions come first. Was the injury or illness caused or made worse by something at work (1904.5)? And is it a new case rather than a recurrence of one already on the log (1904.6)? If the answer to either is no, you don't need to go further. Most cut-and-dried plant floor injuries pass both easily, so let's assume yours does.
Step 2: Check the General Recording Criteria
Under 1904.7(a), a work-related injury or illness is recordable if it results in any of these:
- Death
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional
Most of the gray-area calls come down to the fourth item: was it medical treatment or first aid?
Step 3: Use OSHA's First Aid List. It's the Whole List.
This is the part people miss. OSHA's first aid list in 1904.7(b)(5)(ii) is complete. If a treatment isn't on it, it's medical treatment. You don't get to decide something "feels like first aid."
What counts as first aid
- Non-prescription medication at non-prescription strength
- Tetanus shots (other immunizations, like hepatitis B or rabies, are medical treatment)
- Cleaning, flushing or soaking wounds on the surface of the skin
- Wound coverings like bandages, gauze pads, butterfly bandages and Steri-Strips
- Hot or cold therapy
- Non-rigid support like elastic wraps or non-rigid back belts
- Temporary immobilization devices used only to transport someone (splints, slings, neck collars, back boards)
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Eye patches
- Removing something 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
- Drinking fluids to relieve heat stress
So back to the supervisor's call: cleaned and closed with Steri-Strips is first aid. Not recordable, as long as nothing else on the criteria list applies.
The Gray Areas That Trip People Up
Stitches, staples and skin glue
Steri-Strips and butterfly bandages are first aid. Sutures, staples and surgical glue are wound-closing devices, and OSHA treats them as medical treatment. Same cut, different answer, depending on what the clinic used.
Prescription-strength medication
Over-the-counter medication at over-the-counter strength is first aid. The same drug at prescription strength is medical treatment. Ibuprofen is the one you'll see most: OSHA considers a single dose over 467 mg to be prescription strength. A single prescription dose given at the clinic counts too.
A prescription that was never filled
If a physician or other licensed health care professional recommends medical treatment, OSHA expects the case to be recorded even if the employee never fills the prescription or doesn't follow the advice.
Rigid splints and physical therapy
A rigid splint used to immobilize an injury (not just for transport) is medical treatment. So are physical therapy and chiropractic treatment. Massage is on the first aid list. Physical therapy is not.
X-rays and "just to be safe" clinic visits
Diagnostic procedures like X-rays and blood tests are not medical treatment by themselves. A visit only for observation or counseling isn't either. What matters is what happens after: if the X-ray shows a fracture, the case is recordable as a significant diagnosed injury, even if the only treatment is first aid.
Who gave the treatment doesn't matter
First aid given by a doctor is still first aid. Medical treatment given by a nurse or an EMT is still medical treatment. Judge the treatment, not the person or the setting.
Restricted duty counts even with no treatment
If the doctor says "no lifting over 20 pounds for a week," or you keep someone off a job they'd normally do, the case is recordable as restricted work, no matter how minor the treatment was. Count calendar days, not including the day of the injury, and stop counting at 180.
Don't Forget the Special Cases
A few situations have their own rules: needlestick and sharps injuries with contaminated material (1904.8), hearing loss with a standard threshold shift (1904.10), and tuberculosis cases (1904.11). And separate from the log, a fatality must be reported to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (1904.39).
Make the Decision Defensible
Knowing the rule is half of it. The other half is being able to show your work. When an OSHA inspector, an auditor or your own leadership asks why a case is or isn't on the log, "we talked about it" isn't a great answer.
What works:
- Get the clinic paperwork for every case, and look at what treatment was actually given, not just the diagnosis
- Write down the recordability decision and the reason the same day, while the facts are fresh
- Have a second person review the borderline calls
- Revisit the case if anything changes. A first aid case can become recordable a week later when the follow-up visit adds a prescription or work restrictions
Let the Software Ask the Questions
TruVex walks you through the recordability questions for every injury, from work-relatedness to treatment type to days away, and saves the answers with the case. The body diagram captures what was injured, and recordable cases flow straight onto your OSHA 300 log and 300A summary, so the reasoning behind every call is there when someone asks.
Book a DemoThe Bottom Line
Recordability isn't about how bad an injury looked. It's about what happened next: the treatment, the days away, the restrictions. Learn the first aid list, treat anything not on it as medical treatment, and write down your reasoning every time.
With 300A posting season coming in February, now is a good time to go back through this year's cases and make sure each call holds up. Our free OSHA 300A readiness checklist can help, or book a 15-minute call to talk through a tricky case.
This article is general guidance based on 29 CFR Part 1904 and is not legal advice. For a specific case, check OSHA's recordkeeping regulations and interpretations or talk with a qualified professional. Some states run their own OSHA programs with additional requirements.