29 CFR 1904.7(b)(5)(ii)
The first-aid list is exhaustive. Everything else is medical treatment.
OSHA never defines medical treatment by listing it. It lists first aid — completely — and everything not on that list is medical treatment, which makes a work-related case recordable. All 14 items are below, in the regulation's own words.
Why this one provision decides most cases
Recordability arguments almost never turn on whether an injury happened at work. They turn on whether what the clinic did counts as medical treatment — because medical treatment beyond first aid is one of the six criteria at 1904.7(a), and it is by far the easiest to trip.
The rule is built as a closed list rather than an open definition. That is deliberate, and it has a consequence people find counter-intuitive: severity does not decide the question. A deep, frightening laceration closed with butterfly bandages is not recordable on treatment alone. A trivial cut closed with a single suture is.
It also means you cannot reason by analogy. “Physical therapy is basically massage” is exactly the argument the rule forecloses — inside the item that makes massage first aid.
(i) What is the definition of medical treatment? “Medical treatment” means the management and care of a patient to combat disease or disorder. For the purposes of part 1904, medical treatment does not include:
(iii) Are any other procedures included in first aid? No, this is a complete list of all treatments considered first aid for part 1904 purposes.
1904.7(b)(5)(ii) · 14 items
What counts as first aid
Reproduced verbatim from the eCFR. If a treatment is not described here, it is medical treatment for recordkeeping purposes.
1904.7(b)(5)(ii)(A)
Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
1904.7(b)(5)(ii)(B)
Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
1904.7(b)(5)(ii)(C)
Cleaning, flushing or soaking wounds on the surface of the skin;
1904.7(b)(5)(ii)(D)
Using wound coverings such as bandages, Band-Aids TM , gauze pads, etc.; or using butterfly bandages or Steri-Strips TM (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
1904.7(b)(5)(ii)(E)
Using hot or cold therapy;
1904.7(b)(5)(ii)(F)
Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
1904.7(b)(5)(ii)(G)
Using temporary immobilization devices while transporting an accident victim ( e.g., splints, slings, neck collars, back boards, etc.).
1904.7(b)(5)(ii)(H)
Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
1904.7(b)(5)(ii)(I)
Using eye patches;
1904.7(b)(5)(ii)(J)
Removing foreign bodies from the eye using only irrigation or a cotton swab;
1904.7(b)(5)(ii)(K)
Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
1904.7(b)(5)(ii)(L)
Using finger guards;
1904.7(b)(5)(ii)(M)
Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
1904.7(b)(5)(ii)(N)
Drinking fluids for relief of heat stress.
Text reproduced verbatim from the eCFR, edition 2026-01-01, retrieved 2026-07-19. A US Government work in the public domain under 17 U.S.C. 105.
Side by side
First aid or medical treatment?
Every treatment Job13's engine can classify, which side of the line it falls on, and the reason — in the regulation's terms. “Recordable on treatment alone” means the treatment by itself meets a 1904.7(a) criterion; other criteria such as days away or restricted work can still make a case recordable independently.
| Treatment | Classification | Recordable on treatment alone? | Why |
|---|---|---|---|
| Cleaning, flushing or soaking a surface wound(C) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(C). |
| Drilling a nail to relieve pressure, or draining a blister(H) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(H). |
| Drinking fluids for relief of heat stress(N) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(N). |
| Eye patches(I) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(I). |
| Finger guards(L) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(L). |
| Hot or cold therapy(E) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(E). |
| Massage(M) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(M). Note that physical therapy and chiropractic treatment ARE medical treatment. |
| Non-prescription medication at non-prescription strength(A) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(A). |
| Non-rigid support (elastic bandage, wrap, non-rigid back belt)(F) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(F). |
| Removing an eye foreign body by irrigation or cotton swab(J) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(J). |
| Removing splinters by irrigation, tweezers, cotton swab or simple means(K) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(K). |
| Temporary immobilization while transporting an accident victim(G) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(G). |
| Tetanus immunization(B) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(B). |
| Wound coverings (bandages, gauze, butterfly bandages, Steri-Strips)(D) | First aid | No | Listed as first aid at 1904.7(b)(5)(ii)(D). |
| Diagnostic procedure only (x-ray, blood test, diagnostic medication) | Not medical treatment | No | 1904.7(b)(5)(i)(B) — diagnostic procedures, including administering prescription medication used solely for diagnostic purposes, are not medical treatment. |
| Visit for observation or counseling only | Not medical treatment | No | 1904.7(b)(5)(i)(A) — visits solely for observation or counseling are not medical treatment. |
| Immunization other than tetanus (e.g. Hepatitis B, rabies) | Medical treatment | Yes | 1904.7(b)(5)(ii)(B) makes only tetanus immunization first aid and names Hepatitis B and rabies vaccine as medical treatment. |
| Non-prescription medication used at prescription strength | Medical treatment | Yes | 1904.7(b)(5)(ii)(A) treats a medication available in both forms as first aid only when used at non-prescription strength. |
| Oxygen or intravenous fluids administered | Medical treatment | Yes | Not on the exhaustive first-aid list. |
| Physical therapy or chiropractic treatment | Medical treatment | Yes | 1904.7(b)(5)(ii)(M) states expressly that physical therapy and chiropractic treatment are considered medical treatment. |
| Prescription medication (therapeutic) | Medical treatment | Yes | Not on the exhaustive first-aid list. Only NON-prescription medication at non-prescription strength is first aid — 1904.7(b)(5)(ii)(A). |
| Removing an eye foreign body by means other than irrigation/swab | Medical treatment | Yes | 1904.7(b)(5)(ii)(J) limits first aid to irrigation or a cotton swab. |
| Rigid immobilization (cast, rigid splint) for treatment | Medical treatment | Yes | Only NON-rigid support (F) and temporary immobilization while TRANSPORTING a victim (G) are first aid. |
| Surgical debridement | Medical treatment | Yes | Not on the exhaustive first-aid list. |
| Sutures, staples or surgical glue | Medical treatment | Yes | Not on the exhaustive first-aid list; only butterfly bandages and Steri-Strips are first aid — 1904.7(b)(5)(ii)(D). |
| Wound closure device other than butterfly/Steri-Strip | Medical treatment | Yes | Not on the exhaustive first-aid list — 1904.7(b)(5)(ii)(D). |
| Some other treatment not listed here | Cannot be classified | Needs review | The first-aid list at 1904.7(b)(5)(ii) is exhaustive, so a treatment that is not on it is medical treatment — but we will not guess which treatment you mean. |
A treatment that is not in this table is not necessarily first aid — it is a treatment we will not classify for you. Job13 returns needs review in that case rather than guessing, because the first-aid list is closed and a wrong guess here creates an unrecorded case.
Near misses
The four pairs that catch people
In each pair the injury is identical and the determination is opposite.
Butterfly bandage vs sutures
Butterfly bandages and Steri-Strips are named on the list. Every other wound-closing device is medical treatment — one suture is enough.
Worked example →
Tetanus shot vs hepatitis B
Tetanus immunization is first aid. The same provision names Hepatitis B and rabies vaccine as medical treatment.
Worked example →
Massage vs physical therapy
Massage is first aid. The very same item says physical therapy and chiropractic treatment are medical treatment.
Worked example →
Over-the-counter, prescription strength
The drug's availability is irrelevant. What matters is the dose a licensed professional recommended.
Worked example →
Common questions
Straight answers, with the citation
- Are stitches OSHA recordable?
- Yes — recordable. Recordable — the case meets the 1904.7(a) criterion: Medical treatment beyond first aid. Criteria met: Medical treatment beyond first aid. See the full working →
- Is a tetanus shot OSHA recordable?
- No — not recordable. Work-related, but it meets none of the 1904.7(a) recording criteria, so it is not recordable. See the full working →
- Is physical therapy OSHA recordable?
- Yes — recordable. Recordable — the case meets the 1904.7(a) criterion: Medical treatment beyond first aid. Criteria met: Medical treatment beyond first aid. See the full working →
- Is the OSHA first aid list exhaustive?
- Yes. 29 CFR 1904.7(b)(5)(iii) states: "(iii) Are any other procedures included in first aid? No, this is a complete list of all treatments considered first aid for part 1904 purposes." A treatment that does not appear on the list at 1904.7(b)(5)(ii) is therefore medical treatment, and a work-related case involving it is recordable under 1904.7(a). See the full working →
- Does it matter who provided the treatment?
- No. 29 CFR 1904.7(b)(5)(iv) states: "(iv) Does the professional status of the person providing the treatment have any effect on what is considered first aid or medical treatment? No, OSHA considers the treatments listed in § 1904.7(b)(5)(ii) of this part to be first aid regardless of the professional status of the person providing the treatment. Even when these treatments are provided by a physician or other licensed health care professional, they are considered first aid for the purposes of part 1904. Similarly, OSHA considers treatment beyond first aid to be medical treatment even when it is provided by someone other than a physician or other licensed health care professional." See the full working →
Not legal advice. This page republishes 29 CFR Part 1904 as published by the eCFR and explains it. The recordkeeping duty is the employer’s. Where the rule requires judgement, Job13 says so rather than guessing — run your own case through the free check.