A 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 criteria come from OSHA’s general recording standard (29 CFR 1904.7), and they apply to most private-sector employers in the United States. The distinction matters because recordable injuries must be logged on the OSHA 300 Log, and your company’s recordable injury rate directly affects inspections, insurance costs, and contract eligibility.
The Six Recording Triggers
An injury or illness only needs to meet one of these criteria to be recordable:
- Death
- Days away from work: the employee misses at least one day beyond the day of the injury
- Restricted work or job transfer: the employee can work but can’t perform all normal duties, or is moved to a different role
- Medical treatment beyond first aid: any treatment that goes past the first-aid list (more on this below)
- Loss of consciousness: any duration, even momentary, regardless of whether further treatment is needed
- A significant diagnosis: a physician or licensed healthcare professional diagnoses a significant injury or illness, even if none of the five triggers above apply
That last category is easy to overlook. If a doctor diagnoses a worker with a fractured rib but the worker doesn’t miss any time, doesn’t receive treatment beyond first aid, and never loses consciousness, the case is still recordable because a licensed professional identified a significant condition.
Medical Treatment vs. First Aid
This is where most of the confusion lives. If the only care an injured worker receives qualifies as “first aid,” the case is not recordable (assuming none of the other triggers apply). OSHA defines first aid narrowly. It includes cleaning minor cuts, scrapes, or scratches; treating minor burns; applying bandages or dressings; using non-prescription medications at non-prescription strength; draining blisters; removing debris from the eyes; massage; and drinking fluids to relieve heat stress.
Anything beyond that list counts as medical treatment. Stitches make a laceration recordable. A prescription-strength anti-inflammatory makes a muscle strain recordable. If a worker visits a clinic and the provider does nothing more than clean and bandage a wound, that visit alone doesn’t make the case recordable. But if the provider writes a prescription or applies a butterfly closure strip (which OSHA treats differently from a simple bandage), it crosses the line.
The Injury Must Be Work-Related
A recordable injury has to be connected to the work environment. OSHA presumes work-relatedness when an injury happens on company premises or while the employee is performing work duties. But several exceptions exist, and they come up frequently:
- Symptoms surface at work but result entirely from something that happened outside work
- The employee was voluntarily participating in a wellness program, exercise class, blood donation, or recreational activity
- The injury happened while eating, drinking, or preparing food for personal consumption
- 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 on a company parking lot or access road while the employee was commuting
- The illness is the common cold or flu
- The illness is a mental health condition, unless the employee voluntarily provides a healthcare professional’s opinion that it’s work-related
A worker who sprains an ankle playing in a company-sponsored volleyball game at lunch doesn’t generate a recordable case if participation was voluntary. A worker who slips in the parking lot while walking to their car at the end of a shift, however, is generally considered to be in the work environment, and that case would likely be recordable if it triggers one of the six criteria.
Counting Days Away and Restricted Work
When a recordable injury involves time away from work or restricted duties, you need to count calendar days, not just scheduled workdays. Weekends, holidays, and vacation days all count if the employee couldn’t have worked because of the injury. The count starts the day after the injury occurred, not the day of.
There’s a cap at 180 calendar days. If an employee is out longer than that, you simply enter 180 on the log and stop counting. For restricted work or job transfer cases, the counting rules are identical, with one exception: if you permanently reassign the employee to a modified job that eliminates the restricted functions, you can stop the count when the reassignment becomes permanent. You still must count at least one day.
Special Recording Rules
Needlestick and Sharps Injuries
Any needlestick or cut from a sharp object contaminated with another person’s blood or other potentially infectious material is automatically recordable, regardless of whether the worker develops an illness. A cut from a clean object only becomes recordable if it meets one of the general criteria (stitches, missed work, etc.).
Hearing Loss
Occupational hearing loss has its own threshold. A case is recordable when an employee’s hearing test shows a Standard Threshold Shift, which is a change of 10 decibels or more (averaged across three specific frequencies) compared to the baseline audiogram, and the employee’s total hearing level in that ear is 25 decibels or more above audiometric zero. Employers can apply age-correction tables when determining whether the shift occurred, but cannot use age correction when checking the 25-decibel threshold.
Recordable vs. Reportable
These terms sound similar but trigger very different obligations. Every recordable injury gets logged on the employer’s OSHA 300 Log, which is an internal document kept at the worksite. Reporting means you must actively notify OSHA by phone or online within a set time window.
All employers, regardless of size or industry, must report a work-related fatality within 8 hours. A work-related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours. Many recordable injuries, like a sprained wrist that requires restricted duties, never need to be reported to OSHA at all. They just go on the log.
Which Employers Must Keep Records
Most private-sector employers with 11 or more employees at any point during the previous year must maintain OSHA injury and illness records. Employers with 10 or fewer employees throughout the entire previous year are exempt from routine recordkeeping. Certain low-hazard industries are also partially exempt, including legal services, software publishers, accounting firms, clothing stores, book stores, florists, real estate brokerages, and several others classified under specific NAICS codes.
The partial exemption has limits. Even exempt employers must report fatalities, in-patient hospitalizations, amputations, and eye losses to OSHA. And if OSHA or the Bureau of Labor Statistics specifically requests your records, you must provide them regardless of your exemption status.