A worker gets a two-centimetre cut on the forearm. The nurse cleans it and closes it with a butterfly bandage. Recordable? Not on its own. Send that same worker to urgent care and a physician closes it with two sutures instead, and the case is recordable — same cut, same location, different closure method. That's the whole game with first aid vs medical treatment osha determinations: the rule doesn't ask how bad the injury looked. It asks whether the treatment given appears on one specific, closed list. 29 CFR 1904.7(b)(5)(ii) names exactly 14 items. This post lists all 14, correctly, including the one most "first aid lists" online leave out.
What counts as first aid under OSHA, exactly?
"First aid" isn't a medical judgement here — it's a regulatory term with a fixed, closed list attached to it. 1904.7(b)(5)(ii) names 14 specific treatments. If the care a worker received matches one of those 14 items, it's first aid, and that treatment alone doesn't make the case recordable. If it doesn't match — even if it feels minor, even if a doctor called it "just a precaution" — it's medical treatment beyond first aid. Combined with work-relatedness and a new case, that makes the injury recordable under 1904.7(b)(5). There's no sliding scale and no severity threshold built in. A single suture where a bandage would have worked just as well still counts as medical treatment, because sutures aren't on the list. Nothing else is.
That last point matters more than it sounds. The list is closed by design. OSHA didn't write "for example" or "such as" in front of it — these are the 14 items, full stop, and nothing gets added to it by analogy just because it seems similar in spirit. We cover how this criterion fits into the other five recording triggers in our OSHA recordable criteria checklist, and the wider definition of a recordable case in what makes an injury OSHA recordable.
Why most "OSHA first aid list" articles online get this wrong
Search for an OSHA first aid list and you'll find dozens of pages listing 13 items, or 12, or a version with extra treatments added that were never in the regulation. The most common gap is item 14: drinking fluids for relief of heat stress. It's easy to see why it gets dropped — it doesn't sound like "first aid" in the everyday sense, so writers summarising the rule from memory skip it. But it's in the regulation text exactly like the other 13, and heat-related cases are exactly where it matters most as OSHA's heat illness enforcement attention has grown in recent years. Missing that item means a heat stress case gets marked medical treatment when it should have qualified as first aid, or vice versa if your team isn't checking the actual reg text at all. Job13 keeps the canonical version of this exact list, cited against the regulation, at /first-aid-list — worth bookmarking instead of trusting whichever page ranks first.
The complete 14-item OSHA first aid list
Here is every item, in the order OSHA lists them, with the specific treatment that pushes each one into medical treatment territory instead.
| # | First aid treatment (1904.7(b)(5)(ii)) | Counts as medical treatment instead if… |
|---|---|---|
| 1 | Non-prescription medication at non-prescription strength | A physician or licensed health care professional recommends a non-prescription drug at prescription strength |
| 2 | Tetanus immunisations | Any other immunisation is given (e.g. Hepatitis B, rabies) |
| 3 | Cleaning, flushing, or soaking wounds on the skin surface | — this item has no medical treatment counterpart; it's first aid regardless of wound size |
| 4 | Wound coverings — bandages, Band-Aids, gauze pads, butterfly bandages, Steri-Strips | The wound is closed with sutures, staples, or another wound-closing device |
| 5 | Hot or cold therapy | — always first aid; there is no medical treatment version of this item |
| 6 | Non-rigid support — elastic bandages, wraps, non-rigid back belts | A device with rigid stays, or any system designed to immobilise a body part, is used instead |
| 7 | Temporary immobilisation while transporting a victim — splints, slings, neck collars, back boards | Immobilisation continues as ongoing treatment rather than transport-only support |
| 8 | Drilling a fingernail or toenail to relieve pressure, or draining a blister | — this specific act is always first aid |
| 9 | Eye patches | — always first aid on its own |
| 10 | Removing a foreign body from the eye using irrigation or a cotton swab only | Removal requires any other method or instrument |
| 11 | Removing splinters or foreign material (non-eye) by irrigation, tweezers, cotton swabs, or other simple means | Removal requires a more invasive procedure than these simple means |
| 12 | Finger or toe guards | — always first aid |
| 13 | Massages | Physical therapy or chiropractic treatment is given instead |
| 14 | Drinking fluids for relief of heat stress | Any clinical intervention for heat illness — IV fluids, monitoring, medication — is given instead |
All 14 items in the closed OSHA first aid list under 1904.7(b)(5)(ii), with the treatment that reclassifies each one as medical treatment beyond first aid.
Does the type of drug decide the ibuprofen case, or the dose?
This one trips up more teams than any other item on the list. Ibuprofen is ibuprofen — the drug itself is available both over the counter and by prescription, at different strengths. Item 1 turns on dose, not drug name. A worker taking 400mg ibuprofen from the site first aid kit is first aid. A physician recommending 800mg — the prescription-strength dose of the same drug — is medical treatment, even though no prescription was written and the worker just swallowed a pill in the break room. The determination isn't "was this a prescription drug." It's "was this drug used at prescription strength on a recommendation from a physician or licensed health care professional." We've built out this exact scenario, dose numbers included, in prescription-strength ibuprofen for a back strain.
One EHS manager we spoke with put it this way: "Everyone on my team assumed ibuprofen was automatically fine because you can buy it at any pharmacy without a script. The strength is the whole question. I now make the clinic write the exact mg on the treatment note every time, because without that number I can't make the call."
Is a butterfly bandage the same as stitches for OSHA purposes?
No, and this is the item worth memorising if you only remember one. Butterfly bandages and Steri-Strips are named explicitly in item 4 as first aid. Sutures and staples are named explicitly, in the same clause, as medical treatment. It's not a grey area OSHA left to judgement — the regulation draws the line at the specific device used to close the wound, not the size or depth of the wound itself. A 4cm laceration closed with three butterfly strips is first aid. A 1cm laceration closed with a single suture is medical treatment. We've laid out the exact fact pattern in butterfly bandage vs sutures and a related case in employee gets stitches in the hand, because "how many stitches" is a question people ask that the rule doesn't care about at all — one suture and ten suture both land on the medical treatment side of the line.
What if a doctor calls something "just precautionary"?
It doesn't matter what label the treating clinician puts on the care — what matters is whether the treatment given matches one of the 14 items. A physician can call an X-ray, a round of physical therapy, or a prescription-strength anti-inflammatory "precautionary" or "just to be safe," and none of that changes the recordability analysis. Physical therapy isn't on the list (item 13 covers massage only, and explicitly excludes physical therapy and chiropractic treatment). If PT was given, it's medical treatment, regardless of how routine or low-risk the clinician considered it. The test is what was done, not how anyone characterised it afterwards.
Where teams get this wrong
- Assuming any bandage is automatically first aid. Item 4 covers wound coverings and specific closure methods — bandages, gauze, butterfly strips, Steri-Strips. It does not cover sutures or staples, even though those also "close a wound." The device used is what decides it, not the general category of "bandage-related treatment."
- Missing that dose decides the medication question, not the drug. Teams frequently record the drug name and skip the strength. Non-prescription medication at prescription strength, recommended by a physician, is medical treatment even though the same pill sits on a pharmacy shelf without a script.
- Forgetting the list is closed. Nothing gets added by analogy. If a treatment "feels" first-aid-adjacent but isn't one of the 14 named items — a topical prescription cream, an injection that isn't tetanus, a rigid brace — it's medical treatment. There's no "close enough" clause in the regulation.
- Dropping item 14 entirely. Heat stress cases where a worker was simply given water and a cooldown period are first aid under item 14. Teams that don't know this item exists sometimes escalate a heat stress case to medical treatment unnecessarily, or fail to check it at all because their internal reference list only has 13 items.
- Treating "recommended" the same as "required." A physician recommendation to take a medication at prescription strength triggers medical treatment even if the employee declines to fill it. The recommendation itself is the fact that matters under item 1, not whether the worker acted on it.
Try it against a real case
Run any injury through Job13's free recordability check and it works through the same 14-item list, plus the rest of the 1904.7 criteria, in order. Where the treatment given genuinely sits outside the 14 items or the facts are ambiguous, it returns "needs review" rather than forcing a guess — first aid vs medical treatment calls are exactly the kind of edge case worth getting a second read on before it hits your 300 Log. Paying users can carry the determination straight through to the 300 Log, the 300A summary, and an ITA export. For the exact regulation text behind every item on this list, see 29 CFR Part 1904.
Frequently asked questions
Is a butterfly bandage considered first aid or medical treatment under OSHA?
A butterfly bandage is first aid under item 4 of the 1904.7(b)(5)(ii) list. Sutures and staples, used to close the same type of wound, are medical treatment. The closure method decides it, not the wound's size.
Does non-prescription medication ever count as medical treatment?
Yes. If a physician or licensed health care professional recommends a non-prescription drug at prescription strength — for a drug sold in both forms — that recommendation counts as medical treatment, even though no prescription is written.
Is the OSHA first aid list really limited to 14 items?
Yes. 1904.7(b)(5)(ii) is a closed list of 14 named treatments. Nothing is added to it by analogy or by how minor a treatment seems. Anything given that doesn't match one of the 14 items is medical treatment.
Why do so many online first aid lists only show 13 items?
Most published summaries are written from memory or copied from other secondary sources rather than the regulation text, and item 14 — drinking fluids for relief of heat stress — is the one most often dropped because it doesn't read like a typical first aid treatment. Job13's version at /first-aid-list keeps all 14, matched against the regulation wording.
Where can I check OSHA's official interpretations on first aid determinations?
OSHA publishes Letters of Interpretation addressing specific first aid and medical treatment questions at osha.gov/laws-regs/interpretations. Job13 indexes relevant letters at /interpretations alongside the regulation text.
This article explains how Job13 applies 29 CFR Part 1904 and is not legal advice. Job13 covers federal OSHA recordkeeping rules; it does not currently cover state plan variations.
