Yesterday, we talked about the meaning of "work-related" and how to compute lost workdays under OSHA's recordkeeping standard. Today, we review another important recordkeeping issue—the difference between medical treatment and first aid for recordkeeping purposes.

In a webinar entitled "Safety Recordkeeping: Maintaining Records that Pass Inspection and Build Strong Safety Culture," Adele L Abrams, Esq., CMSP, of the Law Office of Adele L. Abrams PC, discussed several key issues concerning employers' responsibilities under OSHA recordkeeping regulations, including the difference between "medical treatment" and "first aid."

"Medical treatment" means the management and care of a patient to combat a disease or disorder.

For the purposes of Part 1904, medical treatment does not include:

  • Visits to a physician or other licensed health car professional solely for observation or counseling; or
  • The conduct of diagnostic procedures, such as x-rays and blood tests, including the administration of prescription medications used solely for diagnostic purposes (for example, eye drops to dilate pupils); or
  • First aid.

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"First aid" includes:

  • Using a non-prescription medication at nonprescription strength;
  • Administering tetanus immunizations. (Hepatitis B vaccine and rabies vaccine are considered medical treatment.);
  • Cleaning, flushing, or soaking a wound on the surface of the skin;
  • Using wound coverings such as bandages, gauze pads, butterfly bandages or Steri-StripsTM;
  • Using hot or cold therapy;
  • Using any non-rigid means of support, such as elastic bandages, wraps, or non-rigid back belts, etc.;
  • Using temporary immobilization devices while transporting an accident victim;
  • Drilling of a fingernail or toenail to relieve pressure or draining fluid from a blister;
  • Using eye patches;
  • Removing foreign bodies from the eye using only irrigation or a cotton swab;
  • Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means;
  • Using finger guards;
  • Using massages (but physical therapy and chiropractic treatment are considered medical treatment.); and
  • Drinking fluids for relief of heat stress.

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