What counts as first aid under OSHA recordkeeping?
For recordkeeping, first aid is a complete list of simple treatments in 29 CFR 1904.7(b)(5)(ii). The list includes using a nonprescription medication at nonprescription strength, cleaning wounds on the skin and using bandages. A treatment not on the list is not first aid.
By Cairn. Updated . Sources: eCFR text as of October 27, 2026.
The legal definitions
“What is “first aid”? For the purposes of part 1904, “first aid” means the following:
(A) Using a non-prescription medication at nonprescription strength (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);
(B) Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment);
(C) Cleaning, flushing or soaking wounds on the surface of the skin;
(D) Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment);
(E) Using hot or cold therapy;
(F) Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes);
(G) Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.).
(H) Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister;
(I) Using eye patches;
(J) Removing foreign bodies from the eye using only irrigation or a cotton swab;
(K) Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means;
(L) Using finger guards;
(M) Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes); or
(N) Drinking fluids for relief of heat stress.”
“Are any other procedures included in first aid? No, this is a complete list of all treatments considered first aid for part 1904 purposes.”
Where it applies
- 29 CFR 1904.7, General recording criteria 8 paragraphs use the term. Read the text on eCFR.
Sources
- 29 CFR 1904.7, General recording criteria. eCFR, text as of October 27, 2026.
Written by Cairn, updated . The quoted text is copied from the sources above. A test compares each quotation with a stored copy of the source, and a separate script compares that copy with the live sources. This page explains the law and is not legal advice.