An OSHA recordable is any work-related injury or illness that meets specific severity criteria set by the Occupational Safety and Health Administration, requiring the employer to document it on official logs. Not every workplace injury qualifies. A paper cut treated with a bandage isn’t recordable, but a laceration that needs stitches is. The distinction comes down to how serious the outcome is and what kind of treatment was required.
The Six Recording Criteria
Under OSHA’s standard (29 CFR 1904.7), a work-related injury or illness becomes recordable if it results in any one of the following:
- Death
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed healthcare professional, even if none of the above apply
That last category is a catch-all. If a doctor diagnoses a broken bone, for example, it’s recordable regardless of whether the worker missed any time. Only one of these six criteria needs to be met for the case to be recordable.
Medical Treatment vs. First Aid
This is where most of the confusion happens. OSHA draws a hard line between “first aid” and “medical treatment,” and only treatment beyond first aid triggers a recordable. The first aid list is finite and closed, meaning if a treatment isn’t on the list, it counts as medical treatment and makes the case recordable.
Treatments OSHA considers first aid include:
- Non-prescription medications at non-prescription strength
- Tetanus shots (but not hepatitis B or rabies vaccines)
- Cleaning, flushing, or soaking surface wounds
- Bandages, gauze pads, butterfly bandages, or Steri-Strips
- Hot or cold therapy
- Elastic bandages, wraps, or non-rigid back belts
- Temporary splints or slings used only during transport
- Draining a blister or drilling a nail to relieve pressure
- Eye patches
- Removing a foreign body from the eye with irrigation or a cotton swab
- Removing splinters with tweezers or irrigation
- Finger guards
- Massage
- Drinking fluids for heat stress
Anything not on that list is medical treatment. Stitches, staples, prescription medications, rigid braces or casts, physical therapy, and chiropractic treatment all cross the line. So does a recommendation to use an over-the-counter medication at prescription strength. The practical takeaway: the moment a healthcare provider does something that goes beyond basic wound care or comfort measures, you’re likely looking at a recordable.
The Injury Must Be Work-Related
Severity alone doesn’t make a case recordable. The injury or illness also has to be work-related, meaning the work environment either caused it or contributed to it. OSHA presumes work-relatedness for anything that happens in the work environment, but there are notable exceptions. An injury is not considered work-related if:
- The employee was on-site as a member of the general public, not as a worker
- Symptoms surfaced at work but resulted entirely from something outside the workplace
- The injury came from voluntary participation in a wellness program, exercise class, or recreational activity like a company softball game
- The employee was hurt eating, drinking, or preparing personal food (choking on a sandwich, for instance)
- The employee was doing personal tasks outside assigned working hours
- The injury resulted from personal grooming, self-medication for a non-work condition, or was intentionally self-inflicted
- A motor vehicle accident occurred in the company parking lot while commuting to or from work
- The illness is the common cold or flu
- The illness is a mental health condition, unless a qualified mental health professional provides a written opinion that it’s work-related
These exceptions are narrow. If a worker gets food poisoning from food the employer supplied, that is work-related. If contaminated workplace air makes someone sick while eating lunch, that counts too. The exceptions only apply when the non-work cause is the sole factor.
Special Recording Rules
A few types of cases have their own criteria. Work-related hearing loss becomes recordable when a hearing test shows a standard threshold shift of 10 decibels or more (averaged across 2000, 3000, and 4000 Hz) and the employee’s total hearing level in that ear is 25 decibels or more above audiometric zero. Both conditions must be met.
Needlestick injuries and cuts from sharp objects contaminated with another person’s blood or potentially infectious material are always recordable, regardless of what treatment is given.
Privacy Concern Cases
Some recordable injuries involve sensitive information. OSHA requires employers to enter “privacy concern case” on the log instead of the employee’s name for injuries or illnesses involving intimate body parts or the reproductive system, sexual assault, mental illness, HIV infection, hepatitis, tuberculosis, or contaminated needlestick injuries. An employee can also voluntarily request that their name be withheld from the log for any illness.
What Employers Have to Document
Every recordable case gets logged on three forms. The OSHA 300 Log is a running list of all recordable injuries and illnesses throughout the year. The OSHA 301 Incident Report captures the details of each individual case. The OSHA 300A is an annual summary that must be posted in a visible location at the workplace from February 1 through April 30 of the following year, certified by a company executive.
Employers with 100 or more employees in designated high-hazard industries must also electronically submit their 300 Log and 301 data to OSHA each year. Smaller establishments in those industries submit only the 300A summary.
Reporting vs. Recording
Recording a case on the OSHA log is different from reporting it directly to OSHA. Most recordable injuries just go on the log. But the most serious outcomes have strict reporting deadlines: a workplace fatality must be reported to OSHA within 8 hours, and any in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. These timelines start from the moment the employer learns of the event.
Who Is Exempt From Recordkeeping
Not every employer has to keep OSHA injury logs. Businesses with 10 or fewer employees at all times during the previous calendar year are exempt. Certain low-hazard industries are also partially exempt, including legal services, accounting firms, computer systems design, retail clothing and shoe stores, florists, bookstores, and management consulting firms, among others. Even exempt employers still have to report fatalities and severe injuries within the required timeframes, and they must comply if OSHA specifically asks them to keep records during a given year.