Is massage or Active Release Techniques first aid under OSHA?

Yes. Massage is on OSHA's first aid list at 29 CFR 1904.7(b)(5)(ii)(M), and OSHA's May 2, 2024 enforcement memo treats Active Release Techniques (ART) as first aid regardless of who provides it. Physical therapy and chiropractic treatment are named in the same paragraph as medical treatment.

Does a prescription make a case recordable even if it is never filled?

Yes. OSHA records cases in which a physician or other licensed health care professional issues a prescription, whether or not the prescription is filled or the medication is taken. Prescription drugs used only for diagnosis, such as eye drops to dilate pupils, are not medical treatment.

Are x-rays or other diagnostic tests medical treatment?

No. Under 29 CFR 1904.7(b)(5)(i)(B), diagnostic procedures such as x-rays and blood tests are not medical treatment. Visits to a physician or other licensed health care professional solely for observation or counseling are not medical treatment either. Treatment given after the diagnosis is classified on its own.

Does repeated first aid make a case recordable?

Not by itself. First aid remains first aid however many times it is given. OSHA's May 2, 2024 memo does direct inspectors to look at patterns of repeated first aid, because they can indicate that a worker needs medical care that is not being provided.

OSHA First Aid vs. Medical Treatment: Decision Guide

Classify the care given

Select every kind of care the worker received for this injury or illness. Some items ask how it was done.

Medication and immunizations

Non-prescription (over-the-counter) medication
Prescription medicationPrescribed, or recommended by a physician or other licensed health care professional
Immunization

Wounds, skin, and splinters

Cleaning, flushing, or soaking a surface wound
Covering or closing a wound
Drilling a fingernail or toenail, or draining a blisterTo relieve pressure
Removing a splinter or foreign material, not from the eye

Eyes

Eye patch
Removing a foreign body from the eye

Musculoskeletal care

Hot or cold therapyIce, cold packs, heat packs, warm soaks
A support, wrap, brace, or tape
Temporary immobilization while transporting the injured personSplints, slings, neck collars, back boards
Finger guard
Massage
Active Release Techniques (ART)
Physical therapy or chiropractic treatment
Exercise or stretching

Other care and visits

Drinking fluids for relief of heat stress
Diagnostic tests onlyX-rays, blood tests
A visit solely for observation or counselingWith a physician or other licensed health care professional
Any other treatment not listed here

Result

Select the care that was given

Other criteria that make a case recordable

A work-related new case is recordable if it results in any of these, whatever care was given (1904.7(a)):

Death
Days away from work
Restricted work or transfer to another job
Loss of consciousness
A significant injury or illness diagnosed by a physician or other licensed health care professional
The specific cases in 1904.8 to 1904.11: needlesticks and sharps injuries, medical removal, hearing loss, and tuberculosis

Who gave the care does not change the answer: first aid is first aid even when a physician provides it (1904.7(b)(5)(iv)). Repeated first aid is still first aid, though OSHA's 2024 memo asks inspectors to check that needed medical care is not being withheld.

How it works

What OSHA counts as first aid

OSHA defines medical treatment as the management and care of a patient to combat disease or disorder, and then lists the treatments that count as first aid instead. The list is complete: care that is not on it is medical treatment, unless it is a diagnostic procedure or a visit solely for observation or counseling. Who gives the care does not matter.

Non-prescription medication at non-prescription strength
Tetanus immunizations
Cleaning, flushing, or soaking wounds on the surface of the skin
Wound coverings such as bandages, gauze pads, butterfly bandages, or Steri-Strips
Hot or cold therapy
Non-rigid means of support, such as elastic bandages, wraps, or non-rigid back belts
Temporary immobilization devices while transporting an accident victim
Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
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 simple means
Finger guards
Massage (physical therapy and chiropractic treatment are medical treatment)
Drinking fluids for relief of heat stress

Summarized from 29 CFR 1904.7(b)(5)(ii). Read the full text at osha.gov (opens in a new tab).

First aid is one part of recordability

A case is recordable when it is work-related (29 CFR 1904.5), is a new case (1904.6), and meets at least one recording criterion (1904.7): death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional. A case treated only with first aid can still be recordable if, for example, the worker is placed on restricted duty.

For the clinical side of this boundary, and why it matters to the people who provide care on site, read First Aid or Recordable? Why Clinicians Need to Know the Rules.

Questions

More on first aid and recordkeeping

Yes, for recordability. Under 29 CFR 1904.37, states with OSHA-approved State Plans must have recordkeeping requirements that are substantially identical to federal Part 1904, including the same criteria for which cases are recordable. Some State Plans have their own regulations, such as California's Title 8, section 14300, and can differ in other details, so check the rules in the state where the work is done.

Sources

Official OSHA references

Last reviewed October 14, 2026. OSHA materials are cited for reference; this guide is not affiliated with or endorsed by OSHA or the U.S. Department of Labor.

Know where first aid ends

Matheson's Early Intervention and Injury First Aid course applies OSHA's first aid framework to early musculoskeletal care on site, as part of the Certified Worksite Injury Specialist (CWIS) track.

Early Intervention Course Worksite Training & CWIS

Also free: the Injury Rate Calculator