Many EHS professionals wonder whether they are in proper compliance with all of the recordkeeping requirements issued by the Occupational Safety and Health Administration (OSHA). One question they often have, especially in the immediate aftermath of an incident in the workplace, is if the occurrence was a recordable injury (i.e., one that must be included on OSHA 300 forms) or merely required the application of first aid.
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The difference is important! One of the biggest recordkeeping mistakes a safety professional can make is misclassifying a first aid case as a recordable injury or illness. However, it is a mistake that is easily avoided—OSHA provides a great deal of guidance on the distinction between the two types of incidents, and we’ll pass on some of their tips here.
Consult the Lists
The OSHA recordkeeping regulation (29 CFR 1904) covers a great many things, including which employers are covered by the regulation and which are exempt; the various forms on which records must be kept; how to report fatalities and serious injuries and illnesses to the government; and details regarding the electronic submission of OSHA 300A data. It also includes the criteria for determining what is medical treatment (a key term in establishing that an injury is recordable) and what is first aid.
In a helpful summary of injury and illness recordkeeping and reporting requirements, OSHA includes its definitions of recordable cases vs. first aid. OSHA defines a recordable injury or illness as:
- Any work-related fatality (this must be reported to OSHA or its state counterpart within 8 hours).
- Any work-related injury or illness that results in loss of consciousness, days away from work, restricted work, or transfer to another job.
- Any work-related injury or illness requiring medical treatment beyond first aid. Note that employers must report any amputation, loss of an eye, or inpatient hospitalization of a worker to OSHA or its state counterpart within 24 hours.
- Any work-related diagnosis of a significant injury or illness by a healthcare professional, such as cancer, chronic irreversible diseases, fractured or cracked bones or teeth, and punctured eardrums.
- There are also special recording criteria for work-related cases involving:
- Needlesticks and sharps injuries;
- Medical removal;
- Hearing loss; and
- Tuberculosis.
You’ll notice in the third bullet above that a recordable case is one that requires medical treatment beyond first aid. So … what’s considered first aid? Fortunately, OSHA has a clearly defined list for this as well.
OSHA defines first aid as:
- Using a non-prescription medication at nonprescription strength (but be careful; for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes);
- Administering tetanus immunizations (other immunizations, however, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
- Cleaning, flushing or soaking wounds on the surface of the skin;
- Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (but note that wound closing devices such as sutures, staples, etc., are considered medical treatment);
- Using hot or cold therapy;
- Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (however, devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
- Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.);
- 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 (do note, however, that physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
- Drinking fluids for relief of heat stress.
Simply put, if the injury or illness is treated only with items on the above list and does not result in days away from work, work restrictions, or another recordable outcome, do not include it as a recordable incident on your 300 log.
One common misconception regarding the distinction between first aid and medical treatment is that who administers the treatment or where it occurs makes a difference for recordability. That’s false. The determining factor is the actual treatment that was given. The items on the above list are first aid regardless of whether they’re administered in the workplace by a coworker or in the ER by a doctor.
Don’t Report First Aid Cases ‘Just in Case’
Some EHS managers reading this may think to themselves, “Well, I’m going to put any incident that happens in the workplace—including these first aid cases—on my OSHA 300 log anyway. You know, just in case!”
Think again! It is a dangerous recordkeeping misconception to believe that you are going “beyond compliance” by recording your incidents that only require first aid. Minor injuries are exempt from recording, and your organization could actually be cited by OSHA should you decide to record them anyway. Most likely, you would be cited with a de minimis violation (that is, a technical violation of OSHA rules that has no direct impact on health or safety) with no financial penalty. However, keep in mind that if you record all your first aid cases, it will artificially inflate your total number of recordable cases on the 300A form—and, for employers required to submit this information electronically, OSHA uses this data to target its enforcement efforts. Recording cases that aren’t recordable may lead to an increased risk of inspection for your workplace, and if hazards are uncovered during an inspection, costly citations can ensue. A single willful or repeat violation can now cost employers up to $134,937; other violation categories can carry fines up to $13,494.
Employers can certainly choose to track first aid cases for their own internal purposes, and many do—in fact, it can help you identify your organization’s unique hazards and prevent more serious incidents in the future. But these cases don’t belong on your OSHA 300 log.
Proper Recordkeeping Helps Protect Workers Nationwide
Incident and accident management, especially injury and illness recordkeeping, can feel like a chore—but it is nevertheless a very important aspect of safety management. Recordkeeping information allows OSHA to better evaluate the safety of workplaces across the country and helps employers and workers better identify workplace hazards and implement protective measures. This opportunity to prevent future injuries and illnesses in the workplace makes proper data collection and reporting vital to the health of the workforce. While differentiating between medical treatment and first aid may seem trivial, it serves a purpose in painting a clearer picture of the hazards and risks facing workers across industries and job types.
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