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.
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.”
| First aid | Medical treatment |
|---|---|
| Non-prescription medication at non-prescription strength | Prescription medication, or a non-prescription one recommended at prescription strength |
| Tetanus immunization | Other immunizations, such as hepatitis B or rabies vaccine |
| Cleaning, flushing or soaking wounds on the surface of the skin | — |
| Bandages, gauze, butterfly bandages, Steri-Strips | Sutures, staples and other wound closing devices |
| Hot or cold therapy | — |
| Non-rigid support: elastic bandages, wraps, non-rigid back belts | Devices with rigid stays designed to immobilize a body part |
| Temporary immobilization while transporting the victim — splints, slings, collars, backboards | The 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 swab | Removing it by any other means |
| Removing splinters by irrigation, tweezers, cotton swabs or simple means | — |
| Finger guards | — |
| Massage | Physical therapy, chiropractic treatment |
| Drinking fluids for relief of heat stress | Intravenous 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.
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.
| Section | Case type | What it requires |
|---|---|---|
| 1904.8 | Needlesticks and sharps cuts | Record 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. |
| 1904.9 | Medical removal | Record 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. |
| 1904.10 | Hearing loss | Two 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. |
| 1904.11 | Tuberculosis | Occupational 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
- 1Ask what was actually done to the person — not where they went or who saw them.
- 2Check the treatment against the fourteen-item list. On the list, first aid. Not on the list, medical treatment.
- 3Check the outcome separately: any days away, any restriction beyond the day of injury, any loss of consciousness, any significant diagnosis.
- 4Check whether one of 1904.8 to 1904.11 applies and overrides.
- 5If 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.
- 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.