OSHA Recordkeeping: Medical Treatment Versus First Aid
When an employee is injured or suffers illness from a work-related incident, your top priority should always be to administer whatever care is needed immediately. Often, your next step is to record the injury or illness in your OSHA incident log. But did you know that depending on the type of care you provide in response to a work-related injury, you may not need to record it?
OSHA standard 1904.7 requires you to report work-related injuries and illnesses if they involve medical treatment beyond first aid. If you only administer first aid, you do not have to record the injury or illness. Knowing the difference will help you improve the accuracy of your OSHA logs and reduce over-reporting.
OSHA defines medical treatment as the management and care of a patient to combat a disease or disorder. OSHA’s definition of medical treatment does not include visits to a physician or other licensed health care professional solely for observation, counseling, diagnostic procedures or first aid.
The definition of first aid is very specific and only includes the following types of care:
- Using a nonprescription medication at a nonprescription strength
- Administering tetanus immunizations
- Cleaning, flushing or soaking wounds on the surface of the skin
- Using wound coverings such as bandages, gauze pads, etc.; or using butterfly bandages
- Using hot or cold therapy
- Drinking fluids for relief of heat stress
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Drilling of 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
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc.
- Using finger guards
- Using massages
- Using temporary immobilization devices while transporting an accident victim
The line between first aid and medical treatment can be blurry. For example, using nonprescription medication at prescription strength is considered medical treatment, as is using wound closing devices such as sutures and staples. Devices with rigid stays or other systems designed to immobilize parts of the body, and physical therapy or chiropractic treatment are also considered medical treatment, not first aid. Any type of care not listed in the bullet points above constitutes medical treatment and must be recorded.
To help determine whether an injury or illness is work-related and needs to be recorded, use OSHA's Recordkeeping Advisor. This site will guide you through several questions to determine if an incident needs to be reported, whether an exception exists and which provisions of regulations apply.