U.S. · Workplace safety · OSHA recordkeeping
OSHA recordable vs first aid decision tool.
Answer six questions about a work-related injury or illness. The tool applies the general recording criteria and the complete first aid list from OSHA’s recordkeeping rule.
A work-related case is recordable if it involves death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness. First aid is a closed list of 14 treatments in 29 CFR 1904.7(b)(5)(ii). Anything not on the list is medical treatment, whoever provides it.
The case
Result
The six general recording criteria
Section 1904.7(a) says you must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also treat as meeting the criteria a significant injury or illness diagnosed by a physician or other licensed health care professional, even if none of the others happened. Section 1904.7(b)(1) lists the same six and points to the paragraph that explains each. The tool above checks them in that order.
What counts as first aid
Under 1904.7(b)(5)(ii), first aid means only these treatments: a non-prescription medication at nonprescription strength; a tetanus immunization; cleaning, flushing or soaking wounds on the skin surface; wound coverings such as bandages, gauze pads, butterfly bandages or Steri-Strips; hot or cold therapy; non-rigid support such as elastic bandages, wraps or non-rigid back belts; temporary immobilization devices while transporting a victim, such as splints, slings, neck collars or back boards; 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 areas other than the eye by irrigation, tweezers, cotton swabs or other simple means; finger guards; massages; and drinking fluids for relief of heat stress. Paragraph (b)(5)(iii) states that this is a complete list: no other procedure is first aid for Part 1904.
The details matter. A recommendation by a physician or other licensed professional to use a non-prescription medication at prescription strength is medical treatment. Other immunizations, such as hepatitis B or rabies vaccine, are medical treatment. Sutures, staples and other wound-closing devices, rigid stays or other devices designed to immobilize parts of the body, and physical therapy or chiropractic care are medical treatment. Visits solely for observation or counseling and diagnostic procedures such as x-rays and blood tests, including prescription drugs used solely for diagnosis, are not medical treatment either (1904.7(b)(5)(i)).
Who gives the treatment does not matter
Section 1904.7(b)(5)(iv) says the professional status of the person providing treatment has no effect. Treatments on the first aid list remain first aid when a physician provides them, and treatment beyond first aid remains medical treatment when someone without a medical licence provides it. If a clinician recommends medical treatment the employee declines, you still have to record the case (1904.7(b)(5)(v)).
Days away, restriction and the day of injury
Days away are counted from the day after the injury or onset; you count calendar days, including weekends and holidays, when the employee could not have worked, and you may cap the count at 180 days. Restricted work occurs when you keep the employee from one or more routine job functions (work done at least once a week) or from working the full scheduled day, or when a clinician recommends it. A restriction or transfer imposed only for the day of the injury is not recordable. A partial day of work after the day of injury counts as a day of restriction. If a clinician recommends days away but the employee comes to work anyway, you still record days away.
Worked examples
A worker scrapes a forearm, the wound is washed and bandaged and she keeps working: only first aid, not recordable. The same scrape is closed with two stitches: sutures are medical treatment, so it is recordable. A worker strains a back, receives a hot pack and an elastic wrap and works the rest of the shift: first aid. If a physician then recommends that he not lift for a week and lifting is a routine function of his job, restricted work makes it recordable. A worker is diagnosed with a cracked bone after a fall: recordable under the significant-diagnosis rule whatever treatment follows.
Limits of this page
This tool applies only the general criteria in 1904.7. It does not decide whether an injury is work-related (1904.5) or a new case (1904.6), and it does not cover the special recording rules for needlesticks and sharps (1904.8), medical removal (1904.9), hearing loss (1904.10) and tuberculosis (1904.11), or the partial exemptions for employers with 10 or fewer employees (1904.1) and for establishments in certain industries (1904.2). Check those, and ask OSHA or your state plan when a case is close. This is general information, not legal advice.
Sources
Sources opened and read November 2, 2026.
Frequently asked questions
What makes an injury OSHA recordable?
A work-related case is recordable if it results in death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness (29 CFR 1904.7).
What is first aid under OSHA recordkeeping?
Only the 14 treatments listed in 1904.7(b)(5)(ii), such as bandages, cleaning a wound, hot or cold therapy, non-prescription medicine at nonprescription strength and a tetanus shot. The list is complete.
Are stitches recordable?
Yes. Sutures, staples and other wound closing devices are medical treatment. Butterfly bandages and Steri-Strips are first aid.
Does it matter if a doctor gives the first aid?
No. A listed first aid treatment stays first aid even when a physician provides it, and treatment beyond first aid stays medical treatment when anyone provides it.
Is prescription medicine always medical treatment?
A prescription medication is not on the first aid list, so using one is medical treatment, except a prescription drug used solely for diagnostic purposes, such as dilating drops.
Does a day-of-injury restriction make a case recordable?
No. A restriction or transfer that applies only to the day the injury occurred or the illness began is not recordable by itself (1904.7(b)(4)(iii)).
Which injuries are always recordable when diagnosed?
Work-related cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum, recorded at the time of diagnosis (1904.7(b)(7)).
Not legal, tax or financial advice
This page is general information drawn from the sources listed, not legal, tax, safety or financial advice, and it is not run by any government agency. Rules, forms and dates change and your agency or county decides your case, so confirm with the office named on this page before you rely on it. Everything runs in your browser; nothing you enter is sent anywhere.