An OSHA recordable incident is any work-related injury or illness that results in death, days away from work, restricted duties, job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis like a fracture or chronic disease. These six triggers are the core of OSHA’s recordkeeping standard (Part 1904), and they determine whether an employer must log a workplace event on official forms. Understanding what counts as recordable matters whether you’re managing safety compliance or simply trying to figure out if your own workplace injury should have been documented.
The Six Recording Triggers
A workplace injury or illness becomes recordable the moment it meets any one of the following criteria. It only needs to meet one, not all of them.
- Death: Any work-related fatality is recordable, regardless of the time between the injury and the death.
- Days away from work: If the injury or illness keeps the employee from coming to work for one or more days after the day of the incident, it’s recordable.
- Restricted work or job transfer: If the employee can still come to work but can’t perform their normal duties, or gets moved to a different job, the case is recordable.
- Medical treatment beyond first aid: This is the trigger that causes the most confusion. Stitches, prescription medications, and physical therapy all count as medical treatment. Bandages, non-prescription painkillers, and tetanus shots do not. The line between first aid and medical treatment is where many borderline cases are decided.
- Loss of consciousness: Any loss of consciousness, even briefly, makes the case recordable no matter what other treatment is involved.
- Significant diagnosed injury or illness: Cancer, chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum are all recordable at the time of diagnosis, even if the worker never misses a day or receives treatment beyond first aid.
The Work-Relatedness Requirement
Before any of those triggers matter, the injury or illness has to be work-related. OSHA defines this simply: if an event or exposure in the work environment caused the condition, contributed to it, or significantly aggravated a pre-existing condition, it’s work-related. There’s a built-in presumption here. If something happens at work, it’s assumed to be work-related unless a specific exception applies (like symptoms from a common cold that happened to surface at the office).
The “significantly aggravated” rule catches situations people often overlook. Say an employee has a bad knee from an old sports injury, and a slip at work makes it substantially worse, requiring new medical treatment or time off that wouldn’t have happened otherwise. That’s recordable. The original injury doesn’t have to be work-related. What matters is whether the workplace event made a meaningful difference in the outcome.
First Aid vs. Medical Treatment
This distinction is the single most common source of confusion in OSHA recordkeeping. If an injured worker receives only first aid, the case is not recordable (unless it triggers one of the other criteria like lost time or loss of consciousness).
OSHA defines first aid as a specific, closed list. It includes things like cleaning and bandaging surface wounds, using non-prescription medications at nonprescription strength, administering tetanus shots, applying hot or cold therapy, and using finger splints. Anything not on that list is considered medical treatment. So if a doctor prescribes antibiotics for an infected cut, uses sutures to close a wound, or orders a course of physical therapy, the case crosses into recordable territory. The type of provider doesn’t matter. A visit to the ER that results only in first-aid-level care is still just first aid.
How Days Away and Restricted Work Are Counted
When an injury involves time off, you count calendar days, not scheduled work days. That means weekends, holidays, and vacation days all get included if the employee would have been unable to work on those days because of the injury. Counting begins the day after the incident, not the day of.
There’s a cap at 180 calendar days. If an employee is out longer than that, employers can simply enter 180 on the log and stop counting. The same 180-day cap applies to days of restricted work or job transfer.
Recording vs. Reporting: Two Different Obligations
Recording and reporting are related but separate requirements, and mixing them up is common. Recording means logging the incident on your internal OSHA forms and keeping those records at your establishment. Reporting means directly notifying OSHA, and it applies only to the most severe outcomes.
All employers, regardless of size or industry, must report a work-related fatality to OSHA within 8 hours. An in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. These clocks start when the employer learns about the event. If you find out two days later that an employee was hospitalized overnight, your 24-hour reporting window starts at the moment you learned about it, not when the hospitalization happened.
Recording, on the other hand, is the ongoing process of maintaining the OSHA 300 Log throughout the year. Most recordable incidents never need to be reported directly to OSHA. They just need to be logged accurately.
The Three Recordkeeping Forms
OSHA’s recordkeeping system uses three forms that work together. The OSHA 300 Log is a running list of every recordable injury and illness at an establishment during the calendar year. Each entry gets a one- or two-line description. The OSHA 301 Incident Report is a more detailed form completed for each individual case on the log, capturing specifics about how the injury happened. The OSHA 300A Summary tallies up the year’s totals and must be posted in a visible location at the workplace from February 1 through April 30 of the following year.
These records must be kept for five years. Starting in 2024, establishments with 100 or more employees in certain higher-hazard industries are also required to electronically submit data from all three forms through OSHA’s Injury Tracking Application. The submission deadline is March 2 of the year following the calendar year covered by the forms. Smaller establishments in designated industries (those with 20 to 249 employees) have been submitting 300A data electronically for several years already.
Who Is Exempt From Recordkeeping
Two categories of employers get a partial exemption from routine recordkeeping. The first is size-based: companies that had 10 or fewer employees at all times during the previous calendar year don’t need to maintain the OSHA 300 Log or related forms. This is based on peak employment across the entire company, not just one location.
The second exemption is industry-based. Certain lower-hazard industries, like many retail, finance, and service-sector businesses, are partially exempt regardless of their size. These exemptions are listed in OSHA’s regulations under Subpart B.
One critical point: even exempt employers must still comply with the reporting requirements for fatalities, hospitalizations, amputations, and eye losses. The exemption only covers the ongoing logging obligation, not the duty to report severe incidents directly to OSHA.
Why Recordability Matters Beyond Compliance
OSHA recordable rates are one of the most widely used measures of workplace safety performance. Many companies track their Total Recordable Incident Rate (TRIR), calculated using the number of recordable cases, total hours worked, and a standard multiplier of 200,000 (representing 100 full-time workers over a year). Contractors bidding on jobs in oil and gas, construction, and manufacturing are routinely asked for their TRIR, and a high rate can disqualify a company from contracts.
For individual workers, understanding recordability helps you know whether your employer is meeting its legal obligations. If you broke a bone at work and your employer didn’t log it, that’s a recordkeeping violation. OSHA accepts complaints about inaccurate injury logs, and employers can face citations for failing to record qualifying incidents.