First Aid or Medical Treatment? How to Tell the Difference

Posted on 1/30/2018 by Roger Marks

Among OSHA’s injury reporting rules is a requirement for employers to record workplace injuries and illnesses that require “medical treatment beyond first aid.” As is often the case with compliance regulations, OSHA gives very specific meanings to the terms “medical treatment” and “first aid” In the context of workplace accidents.  

The definitions of medical treatment and first aid currently used by OSHA originated in a January 2001 Final Rule that updated OSHA’s injury and illness recordkeeping program, including the introduction of OSHA’s injury Forms 300, 300A, and 301. Employers must understand the difference between first aid and medical treatment to meet their injury and illness reporting and recordkeeping responsibilities.

Basics for Reporting Workplace Injuries

Employers must report all workplace injuries or illnesses that result in: 

  • Death; 
  • Loss of consciousness; 
  • Days away from work; 
  • Restriction to work responsibilities;
  • Job transfer;
  • A significant injury or illness diagnosed by a licensed health care professional; or
  • Medical treatment beyond first aid.

Of these reporting criteria, “medical treatment beyond first aid” is one for which employers request clarification from OSHA most often. 

Defined at 29 CFR 1904.7(b)(5)(i), medical treatment means “management and care of a patient for the purpose of combating a disease or disorder.” 

What’s the Difference Between First Aid and Medical Treatment?

In order to define first aid, OSHA chose to create a comprehensive, or “all-inclusive,” list of first-aid practices in 29 CFR. By comprehensive, OSHA means that if you don’t see it on the list, it’s not considered first aid. 

Found at 29 CFR 1904.7(b)(5)(ii), the list includes things like applying band-aids, gauze pads, and butterfly bandages; use of non-rigid means of support like elastic bandages and wraps; cleaning wounds on the surface of the skin; removing splinters; and drinking fluids to relieve heat stress. 

In the Preamble to the 2001 Final Rule, OSHA provided 5 criteria it used to distinguish first aid from medical treatment when developing the list at §1904.7(b)(5)(ii): 

  1. First aid is usually administered after the injury or illness occurs and at the location where the injury or illness occurred (e.g., the workplace).
  2. First aid generally consists of one-time or short-term treatment.
  3. First-aid treatments are usually simple and require little or no technology.
  4. First aid can be administered by people with little training (beyond first-aid training) and even by the injured or ill person.
  5. First aid is usually administered to keep the condition from worsening, while the injured or ill person is awaiting medical treatment.

[66 FR 5915]

Non-reportable Workplace Injuries and Illness  

In addition to first aid, OSHA allows for two other exclusions from the definition of medical treatment in the Final Rule: 

  • Visits to a healthcare professional solely for observation or counseling; and
  • Diagnostic visits, i.e., x-rays, blood tests, or administration of medication solely for the purpose of diagnosing an injury or illness.

For more guidance on OSHA injury recordkeeping rules, read: OSHA Answers Form 300 Questions.

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Tags: 29, 29 CFR 1904.7, CFR, injuries, osha, reporting and recordkeeping

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