The short version
- 46 CFR 4.05-1(a)(6) is a two part test. For crew, the injury must need treatment beyond first aid AND render them unfit for routine duties. Both, not either.
- The first aid list is not in 46 CFR. NVIC 01-15 adopts the OSHA definitions at 29 CFR 1904.7(b)(5), where first aid is an exhaustive list of fourteen items.
- Prescription status converts an intervention, and purpose converts hardware. A splint used in transport is first aid, a rigid device applied as treatment is not.
- The same injury usually also meets the serious marine incident definition, which starts alcohol testing at 2 hours and drug testing at 32 hours.
- What is in the medicine chest changes how often you report, because the threshold turns on what was administered rather than on how badly someone was hurt.
It is a two part test, and both parts must be true
The phrase that decides whether an injury becomes a federal report is buried in a list of eight casualty types. Most operators remember the first half of it and forget the second, which is how vessels end up filing reports they did not owe and, more dangerously, skipping ones they did.
46 CFR 4.05-1(a)(6)
“An injury that requires professional medical treatment (treatment beyond first aid) and, if the person is engaged or employed on board a vessel in commercial service, floating OCS facility, or MODU in commercial service, that renders the individual unfit to perform their routine duties”[1]
Read the conjunction. For a crewmember, the injury must clear both bars. Treatment beyond first aid alone is not enough, and being unable to stand a watch after an injury treated with a cold pack and an elastic wrap is not enough either. For a passenger or a shoreside visitor the second clause does not apply, because the clause is conditioned on being engaged or employed on board in commercial service. The same event can therefore be reportable for one person on board and not for another.
| Prong | What it asks | Who it applies to |
|---|---|---|
| Treatment | Did the injury require professional medical treatment, meaning treatment beyond first aid[1] | Everyone on board |
| Duty | Did it render the individual unfit to perform their routine duties[1] | Only persons engaged or employed on board in commercial service |
NVIC 01-15 reads the duty prong as injuries that prevent a crewmember from performing normally assigned duties, giving navigation and engineering watches, routine maintenance and cargo handling as the examples[5]. That is a work capability question, not a comfort question.
The list is not in 46 CFR, and that is why the answers online conflict
Search the phrase and the results confidently produce a list of treatments, attributed to 46 CFR. Open 46 CFR and the list is not there. Neither 4.05-1 nor 4.03-2 defines first aid. The regulation uses the phrase and moves on.
The definition lives one level down, in guidance. NVIC 01-15, the Marine Casualty Reporting Procedures Guide with Associated Standard Interpretations issued in July 2015, states that the Coast Guard uses the definitions of medical treatment and first aid as defined by OSHA in 29 CFR 1904.7(b)(5)[5]. OSHA defines medical treatment as the management and care of a patient to combat disease or disorder, and then excludes three things: visits solely for observation or counselling, diagnostic procedures, and first aid[6]. First aid is not described in the abstract. It is an exhaustive list of fourteen lettered items at 1904.7(b)(5)(ii)[6]. If a treatment is on the list it is first aid. If it is not on the list and it is management and care of a patient, it is medical treatment.
The defect worth knowing about
A live capture of the generated summary for this query in August 2026 returned an accurate looking treatment list attributed to 46 CFR 4.03-2, a section that contains no such list. It also stated that administering tetanus immunisations counts as professional medical treatment. The OSHA text says the opposite at (b)(5)(ii)(B): tetanus immunisation is first aid, and it is other immunisations such as hepatitis B and rabies vaccine that are medical treatment. Two of the nine results on that page were state workers compensation pages with no maritime application at all.
The distinctions that decide it on board
Most of the fourteen items are uncontroversial. Six of them carry a parenthetical that flips the answer, and those six are where reporting decisions are actually lost.
| What was done | First aid | Medical treatment |
|---|---|---|
| Medication | Non-prescription medication at non-prescription strength | Any prescription medication, or a non-prescription medication used at prescription strength on professional recommendation[6] |
| Immunisation | Tetanus immunisation | Other immunisations, hepatitis B and rabies vaccine named specifically[6] |
| Wound closure | Bandages, gauze, butterfly bandages and adhesive closure strips | Sutures, staples and other wound closing devices[6] |
| Support and immobilisation | Non-rigid support such as elastic wraps, and temporary immobilisation devices used while transporting the injured person | Devices with rigid stays or systems designed to immobilise part of the body as treatment[6] |
| Eye and skin | Eye patches, irrigation or cotton swab removal of a foreign body from the eye, cleaning and flushing surface wounds | Anything requiring instrumentation of the eye beyond irrigation or a swab[6] |
| Hands on care | Massage, hot or cold therapy, drinking fluids for heat stress | Physical therapy or chiropractic treatment[6] |
Two patterns run through the whole table. Prescription status converts an intervention, regardless of dose or how briefly it was used. And purpose converts hardware, so the same splint is first aid during a transfer and medical treatment when applied as the treatment itself. Neither pattern is intuitive to a mate filling in a log at the end of a watch, which is why the decision should not be left to the person who happened to be on deck.
When the same injury becomes a serious marine incident
The injury wording in 4.03-2 mirrors the casualty trigger almost exactly, so an injury to a crewmember that requires professional medical treatment beyond first aid and renders them unfit for routine duties is generally both a reportable marine casualty and a serious marine incident[3]. That second classification changes the tempo completely, because it starts chemical testing clocks.
| Obligation | Deadline | Where it comes from |
|---|---|---|
| Notice to the Coast Guard | Immediately after addressing resultant safety concerns | 4.05-1(a)[1] |
| Alcohol testing | Within 2 hours of the incident unless precluded by safety concerns, and not required more than 8 hours after | 4.06-3(a)(1)[4] |
| Drug testing | Within 32 hours of the incident unless precluded by safety concerns | 4.06-3(b)(1)[4] |
| Written report | Within 5 days, on Form CG-2692 with the relevant addenda | 4.05-10[2] |
The two hour alcohol window is the operational problem. It expires long before anyone ashore knows whether the treatment given will turn out to have been beyond first aid. The marine employer is required to determine whether the occurrence is, or is likely to become, a serious marine incident[10], and the phrase “is likely to become” is doing the work. A company that waits for certainty has already missed the window. Towing operators inherit all of this through 46 CFR 140.900, which simply requires compliance with part 4[7], as set out in the Subchapter M rules.
Your chest decides your reporting rate
This is the consequence nobody plans for, and it is the reason stocking is a compliance decision rather than a purchasing one. The threshold does not turn on how badly someone was hurt. It turns on what was done about it.
A chest limited to non-prescription strength medication, standard dressings, adhesive closure strips, elastic wraps and cold packs keeps almost every plausible intervention inside the OSHA first aid list. Widen the chest to prescription strength items and any use of them becomes medical treatment by definition, regardless of the severity of the injury that prompted it. The same is true of wound closure: adhesive strips are first aid and staples are not. Fleets that stock upward without thinking about the reporting consequence quietly raise their own casualty report rate, and casualty history is read by charterers, underwriters and inspectors as a safety signal.
The answer is not a thin chest. It is a deliberate one, with the treatment threshold understood at the point the list is written. That reasoning belongs alongside the flag state and route analysis in requirements by flag state and, where anything scheduled is involved, in recordkeeping aboard a vessel and the DEA document checklist. Vessels operating far from shoreside care carry the added problem that treatment escalates because nothing else is available, which is the subject of planning by voyage length and the evacuation decision.
What to write down, and who decides
Four records turn a contested classification into a documented one, and all four are cheap on the day and impossible to reconstruct six months later.
- What was actually administered, by name and strength. Not “treated the wound”. The threshold is item level, so the record has to be item level.
- Whether the person returned to routine duties, and when. This is the second prong and it is the one most often left blank[1].
- The serious marine incident determination and its timestamp. Record that the question was asked, by whom and when, because the two hour clock is judged against that moment[10].
- Who classified it. A named clinician reviewing the treatment record converts a guess into an opinion, and it is the difference between a defensible file and an argument.
The last point is the structural one. This threshold is a medical classification with a legal consequence, made under time pressure by people with no clinical training, and the guidance that governs it sits in a 2015 circular pointing at an OSHA recordkeeping rule. Deciding in advance who reviews it, and giving that person the treatment record rather than a summary, is a single line in a procedure. Where that line sits in a shore organisation is covered in owner or designated person, and how the whole programme is assembled in the six decisions. If you want the classification reviewed by a board certified emergency physician rather than argued about at the office, that is maritime medical consulting. The rest of the library is in the guidance index, and the physician behind it on the about page.
Common questions
Is the first aid list actually in 46 CFR?
No, and this is the single most common mistake. 46 CFR uses the phrase “treatment beyond first aid” without defining it. The definition comes from NVIC 01-15, which states that the Coast Guard uses the definitions of medical treatment and first aid as defined by OSHA in 29 CFR 1904.7(b)(5). Anything citing a treatment list to 46 CFR itself is citing a section that does not contain one.
Does every injury needing treatment beyond first aid have to be reported?
Not on its own. For a person engaged or employed on board a vessel in commercial service the test in 4.05-1(a)(6) is conjunctive: the injury must require professional medical treatment beyond first aid and render the individual unfit to perform their routine duties. Both prongs, not either. The audit view of how these records are checked is in what an audit checks.
A crewmember got a tetanus shot ashore. Is that reportable?
Administering tetanus immunisation is on the OSHA first aid list, so it is not medical treatment on its own. Other immunisations, specifically hepatitis B and rabies vaccine, are treated as medical treatment. This is one of several distinctions where the item, not the setting, decides. What belongs in the chest that shapes these calls is covered in how to stock a chest.
We splinted a suspected fracture and transferred the crewmember ashore. Medical treatment?
Using a temporary immobilisation device while transporting an injured person is first aid under the OSHA list. A device with rigid stays applied as treatment is medical treatment. The distinction is purpose, not hardware, and it is one reason towing vessels are required to carry a splinting capability without that capability alone creating a report. See the Subchapter M rules.
What happens after the injury clears the threshold?
Two things run in parallel. Immediate notice to the nearest Coast Guard unit under 4.05-1, then a written report on Form CG-2692 within five days under 4.05-10. If the same injury also meets the serious marine incident definition, mandatory chemical testing deadlines start immediately. The wider programme these sit inside is the six decisions.
Does the medicine chest change how often we report?
It does, and this is the part almost nobody plans for. The threshold turns on what treatment was given. A chest limited to non-prescription strength medication and standard dressings keeps most interventions inside the first aid list. A chest holding prescription strength items means that using them is medical treatment by definition. Stocking is therefore a reporting decision as well as a clinical one, which is why chest management and the schedules belong in the same conversation.
Does this apply to commercial fishing vessels?
Fishing vessels carry their own reporting duties in addition. 46 CFR 28.80 requires a casualty report and 28.90 requires the injured individual to notify the master or employer within seven days. The full federal picture for that fleet is in the six federal obligations.
