There's More to First Aid than Band Aids©

Defining 'first aid' for OSHA 300 recordkeeping correctly can help employers stop recording injuries they shouldn't.

WHEN an employee is injured on the job, the incident usually triggers a predictable series of events. First and foremost is getting the employee appropriate treatment for the injury.

Second, if blood or body fluids are involved, is cleaning and sanitizing the floor, tools, and equipment to prevent co-workers from exposure. Third is launching an accident investigation to find out what happened and, more importantly, to determine the root cause and correct it. Fourth is filing a worker's compensation claim. And fifth is deciding whether or not the incident meets OSHA's work-related injury and illness recording criteria.

These steps may not be in the exact order your company does them; but chances are, your incident response process includes all of them. The focus of this article is on the fifth point: deciding whether the incident should be recorded on your OSHA 300 Log.

The importance of this decision cannot be underestimated. Too many employers record injuries that don't have to be recorded, skewing their incidence rates and making their safety performance appear questionable. High incidence rates can result in lost contracts and OSHA inspections.

Making informed decisions about recordable cases and documenting only those that meet OSHA's recordability criteria can make a big difference in incidence rates and the totals that appear on the 300A annual summary. And being aware of the following fine points that separate recordables and non-recordables--medical treatment and first aid--is essential to accurate recordkeeping.

What are 'First Aid Treatments'?
When the revised injury and illness recordkeeping rule was published in 2001, OSHA made it clear that the only non-recordable treatments are the 14 items listed under "first aid" at 1904.7(b)(5)(ii). All treatments excluded from the list are considered "medical treatments" and recordable on the 300 Log.

The intent of an all-inclusive first aid list is to take the guesswork out of the decision-making process. First aid treatments are not recordable, regardless of the professional qualifications of the person providing the treatment. It doesn't matter whether the first aid is provided by a physician, registered nurse, other health care professional, or layman, it is considered "first aid" for recordkeeping purposes. Additionally, by excluding minor injuries and illnesses from the recordkeeping process, only the more serious cases are captured on the 300 Log. In general, first aid treatments:
* Are administered after the injury or illness occurs and at the immediate location.
* Consist of a one-time or short-term treatment.
* Are simple and require little or no technology.
* Can be administered by people with little training (beyond first aid training) and even by the injured or ill person.
* Are administered to keep the condition for worsening and/or while awaiting medical treatment.

Observation and Counseling
Visits to a health care professional for observation or counseling are not recordable. Whether the counseling is on an individual basis or offered to large groups of workers who have been exposed to potentially traumatic events, provided by a licensed professional or a layman with limited training, it is not recordable.

Diagnostic Tests
Diagnostic tests and procedures such as blood tests and x-rays, and prescribing or administering prescription medications used solely for diagnostic purposes, such as eye drops to dilate the eyes, are not recordable. It doesn't matter whether the procedures are done in a hospital, clinic, emergency room, or doctor's office, they do not constitute medical treatments.

Over-the-Counter (OTC) Medications
Non-prescription-strength medications such as aspirin and over-the-counter ointments, creams, pills, liquids, sprays, and any other non-prescription medications are considered first aid treatments and are not recordable. However, if a drug is available in both prescription and non-prescription strengths, such as ibuprofen, and it is prescribed at prescription strength, the medical treatment criterion is met and the case has to be recorded. This applies whether the physician wrote a prescription or told the employee to obtain the medication over the counter and use it at prescription strength. According to OSHA, both cases received equal treatment and should be recorded equally.

The prescription strength of OTC medications is determined by the measured quantity of the therapeutic agent to be taken at one time (i.e., a single dose). The single dosages that are considered prescription strength for four common over-the-counter drugs are:

  • Ibuprofen (such as Advil[TM]): greater than 467 mg,
  • Diphenhydramine (such as Benadryl[TM]): greater than 50 mg,
  • Naproxen Sodium (such as Aleve[TM]): greater than 220 mg, and
  • Ketoprofen (such as Orudus KT[TM]): greater than 25mg.

To determine the prescription-strength dosages for other drugs that are available in prescription and non-prescription formulations, contact OSHA, the U.S. Food and Drug Administration, a pharmacist, or a physician.

Note: The use of prescription medication as an antibiotic or antiseptic administered following an injury to prevent a possible infection is considered medical treatment.

Oxygen
When oxygen is administered as a purely precautionary measure to an employee who does not exhibit any symptom of an injury or illness, the case is not recordable. However, if the employee is exposed to a hazardous substance and exhibits symptoms, administering oxygen is considered a form of medical treatment, making the case recordable.

Inoculations and Immunizations
Immunizations and inoculations that are provided for public health, such as a flu shot, or when there is no work-related injury or illness, are not considered either first aid or medical treatment and do not, of themselves, make a case recordable. However, when an inoculation is given in response to a workplace exposure, then medical treatment has been provided and the case is recordable.

Example: If a health care worker is given a hepatitis B shot during the initial hiring process, the action is considered first aid and not recordable. However, if the same health care worker has an occupational exposure to a splash of potentially contaminated blood and a hepatitis B shot is given as a preventive measure, it is considered medical treatment and recordable.

Tetanus immunizations are always considered first aid because they are usually administered to a worker routinely to maintain a required level of immunity to the tetanus bacillus. These immunizations are based not on the severity of the injury, but on the length of time since the worker has last been immunized.

Chiropractic Treatments
Whether or not an employee's visit to a chiropractor is recordable depends on what occurred during the visit. In the preamble to the recordkeeping rule, OSHA states:

"If a chiropractor provides observation, counseling, diagnostic procedures, or first aid procedures for a work-related injury or illness, the case would not be recordable. On the other hand, if a chiropractor provides medical treatment or prescribes work restrictions, the case would be recordable."

Chiropractic manipulation is a treatment used for more serious injuries and is provided by licensed personnel with advanced training. OSHA considers chiropractic manipulation to be at the level of medical treatment and beyond first aid.

Wound Coverings
OSHA's list of wound coverings that are considered to be first aid treatments includes:

  • Bandages
  • Band Aids©
  • Gauze pads
  • Butterfly bandages
  • Steri-Strips©
  • Liquid bandages

These items fall under the first aid category because they are relatively simple and require little or no training to apply. Wound closing devices such as sutures, surgical staples, tapes, and glues are considered medical treatment and recordable.

Hot and Cold Therapy
Hot and cold therapy is classified as a first aid treatment, regardless of the number of applications, the length of time that it is applied, where it is applied, or the injury or illness for which it is used. These treatments are simple to apply, do not require special training, and are rarely used as the only treatment for any significant injury or illness.

Finger Guards and Elastic Wraps
The use of rigid finger guards is always considered a first aid treatment. However, other types of rigid orthopedic devices that are designed to immobilize a body part, such as splints, casts, and braces, are forms of medical treatment. Wraps or non-constraining devices, including wristlets, tennis elbow bands, elastic bandages, and non-rigid back belts, are non-recordable first aid treatments, regardless of how long or how often they are used.

Burns
The size or degree of a work-related burn does not determine its recordability. Most first-degree burns and minor second-degree burns will not be recorded because they don't need medical treatment. More serious first- and second-degree burns that receive medical treatment and all third-degree burns are recordable. Any first-, second-, or third-degree burn that results in one or more of the recordability criteria must be recorded.

Removing Splinters
Removing splinters or foreign material from areas other than the eye by flushing or using tweezers, cotton swabs, needles, pins, or small tools is considered first aid.

Value in Knowing the Fine Points
It pays to understand the fine points of OSHA's designated first aid treatments to make your injury and illness recordkeeping reflect reality. Making informed decisions about which cases to record on the 300 Log can lower your incidence rate. A rate well below the national average will make a favorable impression on your customers and show both management and employees the true picture of safety in their company.

This article appeared in the April 2005 issue of Occupational Health & Safety.

This article originally appeared in the April 2005 issue of Occupational Health & Safety.

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