Privacy Concern Cases

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Privacy Concern Cases

Reference Number: MTAS-864
Reviewed Date: 09/04/2026

If a work-related injury or illness results in medical treatment beyond first aid, the city must record the case on the OSHA/TOSHA 300 Log. If the case does not result in death, days away from work, restricted work, or a job transfer, the city must check the “other recordable cases” box on the OSHA/TOSHA 300 Log.

For example, if an employee sustains a work-related cut, receives sutures at a hospital or medical clinic, and returns to regular work the next day without work restrictions, the employee has received medical treatment beyond first aid. The city must record the case as an other recordable case because sutures are medical treatment, even though the employee did not have days away from work, restricted work, or a job transfer.

For OSHA/TOSHA recordkeeping purposes, medical treatment means the management and care of a patient to combat disease or disorder. Medical treatment does not include:

  • Visits to a physician or other licensed health-care professional solely for observation or counseling.
  • Diagnostic procedures, such as X-rays, blood tests, or other diagnostic testing.
  • Administration of prescription medication used solely for diagnostic purposes, such as eye drops used to dilate pupils for an eye examination.
  • First aid as defined in 29 C.F.R. § 1904.7(b)(5)(ii).

First Aid
For OSHA/TOSHA recordkeeping purposes, first aid includes only the following treatments:

  • Using nonprescription medication at nonprescription strength. A nonprescription medication used at prescription strength is medical treatment when directed by a physician or other licensed health-care professional.
  • Administering tetanus immunizations. Other immunizations, including hepatitis B or rabies vaccinations, are medical treatment for recordkeeping purposes.
  • Cleaning, flushing, or soaking wounds on the surface of the skin.
  • Using wound coverings, including bandages, Band-Aids, gauze pads, butterfly bandages, or Steri-Strips. Sutures, staples, surgical glue, and other wound-closing devices are medical treatment.
  • Using hot or cold therapy.
  • Using non-rigid means of support, including elastic bandages, wraps, or non-rigid back belts. Devices with rigid stays or other systems intended to immobilize a body part are medical treatment.
  • Using temporary immobilization devices to transport an accident victim, including splints, slings, neck collars, and backboards.
  • Drilling 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 massage. Physical therapy and chiropractic treatment are medical treatment.
  • Drinking fluids to relieve heat stress.

Because this is an exclusive list, treatment not included in the list is medical treatment beyond first aid and may make a work-related injury or illness recordable.

Recommended Treatment
If a physician or other licensed health-care professional recommends medical treatment for a work-related injury or illness, the city must record the case even if the employee chooses not to follow the recommendation. The city should encourage the employee to follow the provider’s recommendation and document the recommendation and its recordkeeping decision.