Skip to content
STEELTOETOOLS
Part 111 min

1.3 The six criteria and the closed first aid list

Once a case is work-related and new, one question remains: did anything happen that Part 1904 counts? The answer is in 29 CFR 1904.7(a), which lists six outcomes — and in a list of fourteen treatments that is unusual in American regulation because it is deliberately closed. Anything not on that list is medical treatment, and medical treatment is recordable.

1 Six outcomes, any one of which records the case

1904.7(a) is short. A work-related injury or illness meets the general recording criteria if it results in any of: death; days away from work; restricted work or transfer to another job; medical treatment beyond first aid; loss of consciousness; or a significant injury or illness diagnosed by a physician or other licensed health care professional.

Death
Days away
Restriction or transfer
Treatment beyond first aid
Loss of consciousness
Significant diagnosis

Two of them deserve a note now. Loss of consciousness is recordable however brief — 1904.7(b)(6) says so in one sentence, and it means a worker who blacks out for three seconds in the heat and returns to work produces a recordable case. And the significant diagnosis criterion in (b)(7) catches conditions that produce no treatment and no lost time at the moment of diagnosis: the rule names four that must always be recorded at the time of diagnosis — cancer, chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum.

2 Medical treatment, defined by exclusion

1904.7(b)(5)(i) defines medical treatment as the management and care of a patient to combat disease or disorder, and then excludes three things: visits to a health care professional solely for observation or counseling; diagnostic procedures including prescription medications used solely for diagnostic purposes; and first aid, as defined in the section.

That third exclusion is the operative one, and it is where the fourteen-item list comes in. The list is not a set of examples. 1904.7(b)(5)(iii) asks the question directly — “Are any other procedures included in first aid?” — and answers: “No, this is a complete list of all treatments considered first aid for part 1904 purposes.”

The closed first aid list of 1904.7(b)(5)(ii), and its built-in contrasts
First aidMedical treatment
Non-prescription medication at non-prescription strengthPrescription medication, or a non-prescription one recommended at prescription strength
Tetanus immunizationOther immunizations, such as hepatitis B or rabies vaccine
Cleaning, flushing or soaking wounds on the surface of the skin—
Bandages, gauze, butterfly bandages, Steri-StripsSutures, staples and other wound closing devices
Hot or cold therapy—
Non-rigid support: elastic bandages, wraps, non-rigid back beltsDevices with rigid stays designed to immobilize a body part
Temporary immobilization while transporting the victim — splints, slings, collars, backboardsThe same devices used as ongoing treatment
Drilling a nail to relieve pressure, draining a blister—
Eye patches; removing a foreign body from the eye using only irrigation or a cotton swabRemoving it by any other means
Removing splinters by irrigation, tweezers, cotton swabs or simple means—
Finger guards—
MassagePhysical therapy, chiropractic treatment
Drinking fluids for relief of heat stressIntravenous fluids

3 Two rules that settle most arguments

The first is 1904.7(b)(5)(iv): the professional status of the person providing the treatment changes nothing. A physician applying a cold pack is still doing first aid; a supervisor handing out a prescription-strength medication is still administering medical treatment. This kills the “but a doctor did it” argument and the “but it was only the site first-aider” argument in the same breath.

The second is (b)(5)(v): if a health care professional recommends medical treatment and the employee does not follow the recommendation, you must record the case anyway — and you should encourage the employee to follow it. The same structure appears for days away in (b)(3)(ii) and for restrictions in (b)(4)(viii). Recordkeeping follows the medical recommendation, not the employee's compliance with it.

On the job: the clinic prescribes a muscle relaxant. The worker says “I'm fine, I won't fill it” and finishes the shift. The case is recordable — medical treatment was recommended. Have that conversation before you tell a superintendent the case is clean.

4 The specific case types, and what they change

Four sections handle case types where the general criteria alone would give the wrong answer. Each one is short and each one overrides.

Cases with their own criteria — 1904.8 to 1904.11
SectionCase typeWhat it requires
1904.8Needlesticks and sharps cutsRecord all work-related needlesticks and cuts from sharps contaminated with another person's blood or other potentially infectious material — as an injury, and as a privacy case. A cut from a clean object is judged on 1904.7.
1904.9Medical removalRecord any removal under the medical surveillance requirements of an OSHA standard, as days away or restricted work depending on how you comply. Voluntary removal before the standard's trigger is not recorded.
1904.10Hearing lossTwo conditions together: a work-related Standard Threshold Shift — 10 dB average at 2000, 3000 and 4000 Hz against the baseline — and a total hearing level of 25 dB or more above audiometric zero in the same ear. Age adjustment is allowed for the STS, not for the 25 dB level.
1904.11TuberculosisOccupational exposure to a known case of active TB followed by infection, evidenced by a positive skin test or a diagnosis.

The hearing loss rule has a useful practical clause. 1904.10(b)(4) lets you retest within 30 days; if the retest does not confirm the shift, nothing is recorded, and if it does, you have seven calendar days from the retest.

5 Working the call, in order

  1. 1
    Ask what was actually done to the person — not where they went or who saw them.
  2. 2
    Check the treatment against the fourteen-item list. On the list, first aid. Not on the list, medical treatment.
  3. 3
    Check the outcome separately: any days away, any restriction beyond the day of injury, any loss of consciousness, any significant diagnosis.
  4. 4
    Check whether one of 1904.8 to 1904.11 applies and overrides.
  5. 5
    If any test comes out yes, the case is recordable. Write down which one and why.

6 The case everybody under-records

It is the one that ends with stitches, a prescription or a course of physical therapy, and nobody missing a shift. No days away, no restriction, no drama. On the 300A it belongs in column J, other recordable cases, and column J is the emptiest box on most summaries that have been kept carelessly.

Common mistake: treating “nobody lost time” as the test. Medical treatment beyond first aid is a criterion on its own. A log with plenty of column H and an empty column J is usually not a safe workplace — it is an incomplete log.
Key takeaways
  • Six criteria: death, days away, restriction or transfer, medical treatment beyond first aid, loss of consciousness, significant diagnosis
  • The first aid list of 1904.7(b)(5)(ii) is complete and closed — anything not on it is medical treatment
  • Sutures and staples are treatment; butterfly bandages and Steri-Strips are first aid
  • Prescription strength makes it treatment, whoever prescribed it and whoever administered it
  • A recommended treatment or restriction the employee ignores is still recorded
  • Needlesticks, medical removal, hearing loss and TB have their own criteria in 1904.8 to 1904.11

Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.