An OSHA recordable injury is any work-related injury or illness that results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis from a licensed healthcare professional. These are the six recording criteria set by the Occupational Safety and Health Administration, and if a workplace injury triggers even one of them, the employer is legally required to document it on specific OSHA forms.
The distinction matters because not every workplace injury counts. A paper cut, a minor bruise, or a scrape that only needs a bandage won’t appear on any OSHA log. The line between recordable and non-recordable comes down to severity, and understanding where that line falls is useful whether you’re an employee, a supervisor, or someone managing workplace safety.
The Six Recording Criteria
A work-related injury or illness becomes recordable the moment it meets any one of these conditions:
- Death: Any work-related fatality is recordable and must also be reported to OSHA within 8 hours.
- Days away from work: If the injury keeps you from coming to work for one or more days beyond the day it happened, it’s recordable. Counting starts the day after the injury.
- Restricted work or job transfer: If you can still come to work but can’t perform your normal duties, or you’re moved to a different job because of the injury, that counts.
- Medical treatment beyond first aid: This is the criterion that causes the most confusion, and it has a very specific definition (covered in the next section).
- Loss of consciousness: Any loss of consciousness at all, even momentary, makes the case recordable regardless of the cause.
- Significant diagnosis: If a physician or licensed healthcare professional diagnoses a significant injury or illness, it’s recordable even if none of the other five criteria apply. This catches conditions like a fractured rib that doesn’t yet require treatment or time off work.
Medical Treatment vs. First Aid
This is where most of the gray area lives. OSHA draws a hard line between “first aid” and “medical treatment,” and only medical treatment triggers recordability. First aid includes cleaning minor cuts, scrapes, or scratches; treating a minor burn; applying bandages and dressings; using non-prescription medications; draining blisters; removing debris from eyes; massage; and drinking fluids to relieve heat stress. If the only treatment an injured worker receives falls into that list, the case is not recordable.
Anything beyond that list counts as medical treatment. Stitches to close a wound, prescription medications, physical therapy, surgical procedures: all of these push an injury into recordable territory. The key question isn’t where the treatment happens (an emergency room visit doesn’t automatically make a case recordable) but what treatment is actually provided. A worker who goes to the ER, gets cleaned up, and leaves with a bandage received first aid. A worker who goes to the ER and gets a prescription painkiller received medical treatment.
What “Work-Related” Actually Means
Before any of the recording criteria matter, the injury has to be work-related. OSHA presumes work-relatedness for any injury or illness caused by an event or exposure in the work environment, or one that significantly aggravates a pre-existing condition. But several specific exceptions exist.
An injury is not considered work-related if the employee was present at the workplace as a member of the general public rather than as an employee. It’s also not work-related if it results solely from voluntary participation in a wellness program, recreational activity, blood donation, or flu shot. Injuries from eating or preparing personal food don’t count either, so choking on your own sandwich at your desk isn’t recordable (though getting sick from food contaminated by workplace chemicals would be).
Other exceptions include injuries from personal grooming or personal tasks done outside assigned working hours, self-inflicted injuries, the common cold or flu, and car accidents that happen in the company parking lot while commuting. Mental illness is also excluded unless the employee voluntarily provides a healthcare professional’s opinion connecting it to work.
The Three OSHA Forms
When an injury is recordable, employers document it using three forms that serve different purposes.
The OSHA Form 300 is the Log of Work-Related Injuries and Illnesses. It’s essentially a running spreadsheet for the year, with one line per case. Each entry includes a description of the injury, which recording criteria it met, and how many days away or restricted days were involved. The OSHA Form 301 is the Incident Report, a more detailed form that captures what the employee was doing when injured, how the incident happened, the specific nature of the injury, and what object or substance caused harm. It also records details about any medical treatment received.
The OSHA Form 300A is the Annual Summary. At the end of the year, employers total up the entries from the 300 Log and post this summary in a visible location from February 1 through April 30 of the following year so employees can see the overall injury and illness picture for their workplace. All three forms must be kept on file for five years after the end of the calendar year they cover.
Reporting vs. Recording
Recording and reporting are two separate obligations that people often mix up. Recording means logging the injury on the forms described above. Reporting means directly notifying OSHA, and it’s only required for the most severe events. A fatality must be reported within 8 hours. An inpatient hospitalization, amputation, or loss of an eye must be reported within 24 hours. These reporting requirements apply to every employer, including those who are otherwise exempt from routine recordkeeping.
Who Is Exempt From Recordkeeping
Not every business has to maintain OSHA injury and illness logs. Two categories of employers get a partial exemption. First, businesses with 10 or fewer employees at all times during the previous calendar year don’t need to keep routine records. Second, businesses in certain low-hazard industries (identified by specific industry classification codes) are also exempt from routine recordkeeping.
The word “partial” matters here. Even exempt employers must report fatalities, hospitalizations, amputations, and eye losses to OSHA within the required timeframes. And if OSHA or the Bureau of Labor Statistics asks an exempt employer in writing to keep records, they have to comply.
Electronic Submission Requirements
Larger employers in high-hazard industries face an additional obligation. Establishments with 100 or more employees in designated industries must electronically submit their Form 300 Log and Form 301 Incident Report data to OSHA each year. This submission includes the date, location, and severity of each injury, details about the injured worker, and information about how it happened. The deadline is March 2 of the year following the calendar year covered by the forms.
OSHA provides a secure Injury Tracking Application for submission, which accepts manual data entry through a web form, CSV file uploads for multiple establishments, and direct transmission through an API for companies using automated recordkeeping systems. Smaller establishments (those with 20 to 249 employees in certain industries) only need to submit their Form 300A Annual Summary data electronically, not the detailed case-level information.