OSHA Recordability Determination Tool

The Rule

OSHA defines medical treatment as "the management and care of a patient to combat disease or disorder." However, OSHA excludes three categories:

Observation or counseling — visits solely for observation
Diagnostic procedures — X-rays, CT scans, MRIs, blood tests, and medications used solely for diagnostic purposes
First aid — the specific treatments listed below

Important: If a physician recommends medical treatment but the employee does not follow the recommendation, you must still record the case. The recommendation alone triggers recordability.

29 CFR 1904.7(b)(5)(ii)— These are NOT recordable

The Complete First Aid List

This is the complete, exhaustive list. Any treatment NOT on this list is medical treatment.

Non-prescription medication at nonprescription strength

Note: If recommended at prescription strength, it becomes medical treatment

Tetanus immunizations

Note: Other immunizations (Hepatitis B, rabies) are medical treatment

Cleaning, flushing, or soaking wounds on the skin surface

Wound coverings (bandages, Band-Aids, gauze pads, butterfly bandages, Steri-Strips)

Note: Sutures, staples, and surgical glue are medical treatment

Hot or cold therapy

Non-rigid means of support (elastic bandages, wraps, non-rigid back belts)

Note: Devices with rigid stays designed to immobilize are medical treatment

Temporary immobilization devices while transporting (splints, slings, neck collars, back boards)

Note: Only qualifies as first aid when used during transport

Drilling a fingernail/toenail to relieve pressure, or draining fluid from a blister

Eye patches

10.

Removing foreign bodies from the eye using irrigation or a cotton swab

Note: If anesthetic eye drops are used during removal, the case becomes recordable (see edge cases below)

11.

Removing splinters or foreign material using tweezers, irrigation, or other simple means

12.

Finger guards

13.

Massages

Note: Physical therapy is medical treatment, not first aid

14.

Drinking fluids for relief of heat stress

15.

Oxygen administered as a precautionary measure

Note: Oxygen to treat an injury/illness is medical treatment

Medical Treatment— These ARE recordable

Common Medical Treatments (Recordable)

Prescription medications

Only OTC meds at OTC strength qualify as first aid. This includes anesthetic eye drops.

Sutures, staples, or surgical glue

Only butterfly bandages and Steri-Strips are first aid

Rigid braces, casts, rigid splints

Only non-rigid supports (elastic wraps) are first aid

Physical therapy or chiropractic treatment

Massages are first aid but PT is not

Surgery of any kind

Not on the first aid list

Hepatitis B or rabies vaccines

Only tetanus immunizations are first aid

OTC medication at prescription strength

First aid only covers OTC meds at nonprescription strength

Common Edge Cases

Diagnostic Procedures (X-rays, CT Scans, MRIs) Are NOT Medical Treatment

X-rays, CT scans, MRIs, blood tests, and other diagnostic imaging are NOT considered medical treatment when used solely for diagnostic purposes. An employee can visit the ER, get a CT scan, and be sent home with OTC ibuprofen — that case is not recordable based on medical treatment alone. The imaging is a diagnostic procedure, and OTC medication at OTC strength is first aid.

Anesthetic Eye Drops Make Eye Foreign Body Removal Recordable

While removing a foreign body from the eye using irrigation or a cotton swab is first aid, the use of anesthetic eye drops (e.g., tetracaine, proparacaine) during the procedure changes the determination. Anesthetic eye drops are prescription medications, and the use of any prescription medication constitutes medical treatment beyond first aid — making the case recordable, even if the removal method itself (irrigation, cotton swab) would otherwise be first aid.

Observation Visits Are NOT Medical Treatment

Physician visits solely for observation or counseling with no treatment provided do not make a case recordable.

The Recommendation Rule

If a physician recommends medical treatment (e.g., prescribes a medication), the case is recordable even if the employee declines to follow the recommendation.

Physical Therapy vs. Massage

Massage is first aid. Physical therapy is not. A single PT evaluation resulting only in home exercise recommendations may be considered observation, but ongoing PT sessions are medical treatment.

How Recordability Affects Your Business

EMR Impact: Recordable injuries increase your Experience Modification Rate, directly multiplying your workers' comp premium by 15-30% for three years.

Inspection Targeting: High recordable rates can trigger OSHA Site-Specific Targeting inspections.

Contract Eligibility: Many companies require subcontractors to maintain low recordable rates (TRIR below 1.0) for contract eligibility.

Coming Soon: EMR Impact Calculator

Model how recordable injuries affect your workers' comp premiums. Understand the true financial impact of treatment decisions.

Medical Treatment vs. First Aid