The facts
- A kitchen worker cuts a forearm on a broken container.
- The clinic pulls the edges together with two butterfly bandages and dresses the wound with gauze.
- No prescription, no restriction, no lost time.
The determination
Not recordable
Work-related, but it meets none of the 1904.7(a) recording criteria, so it is not recordable.
Decision trail
- 01
Did an event or exposure in the work environment cause or contribute to the case?
Yes — presumed work-related, subject to the 1904.5(b)(2) exceptions.
29 CFR § 1904.5(a)(a) Basic requirement. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in § 1904.5(b)(2) specifically applies.
- 02
Is this a new case?
Yes.
29 CFR § 1904.6(a)(a) Basic requirement. You must consider an injury or illness to be a “new case” if:
- 03
Does the case meet one or more of the general recording criteria in 1904.7(a)?
No — the only treatment provided appears on the exhaustive first-aid list.
29 CFR § 1904.7(a)(a) Basic requirement. 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 consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
29 CFR § 1904.7(b)(5)(iii)(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.
Computed at build time by Job13’s engine from the facts above — not written by hand. Change the facts and re-run it yourself →
What is actually going on here — Job13's explanation
Item (D) of the first-aid list names butterfly bandages and Steri-Strips specifically — and only those. Every other wound-closing device is medical treatment.
That makes this pair the cleanest demonstration of how Part 1904 actually works. The injury, the anatomy and the severity are identical; the determination turns entirely on which product came out of the drawer.
It follows that a clinician's choice can create a recordable case. That is not a reason to lean on anybody's clinical judgement — it is a reason to record what was actually done, accurately, and to be able to show the provision you relied on.
The provisions this turns on
In the regulation's own words
(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);
(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.
Change one fact
If sutures had been used instead
Sutures, staples and surgical glue are not on the list, so the same laceration becomes a recordable case.
The determination on those facts instead
Recordable
Recordable — the case meets the 1904.7(a) criterion: Medical treatment beyond first aid.
Criteria met
- • Medical treatment beyond first aid
Decision trail
- 01
Did an event or exposure in the work environment cause or contribute to the case?
Yes — presumed work-related, subject to the 1904.5(b)(2) exceptions.
29 CFR § 1904.5(a)(a) Basic requirement. You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in § 1904.5(b)(2) specifically applies.
- 02
Is this a new case?
Yes.
29 CFR § 1904.6(a)(a) Basic requirement. You must consider an injury or illness to be a “new case” if:
- 03
Does the case meet one or more of the general recording criteria in 1904.7(a)?
Yes — Medical treatment beyond first aid.
29 CFR § 1904.7(a)(a) Basic requirement. 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 consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.
29 CFR § 1904.7(b)(5)Not on the exhaustive first-aid list; only butterfly bandages and Steri-Strips are first aid — 1904.7(b)(5)(ii)(D).
Your case is not this case
Scenarios are worked examples on stated facts. Small differences — who recommended the treatment, whether participation was voluntary, what the employee’s routine functions actually are — change the answer. Run your own facts, and the determination will show you which step decided it.
Check your case — freeNot 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.