A workplace injury or illness becomes OSHA recordable when it is work-related and results in at least one of these outcomes: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury diagnosed by a healthcare professional. If the incident doesn’t hit any of those triggers, it’s a first-aid case and stays off the OSHA 300 Log. The distinction often comes down to exactly what treatment was provided.
The Six Recording Triggers
OSHA’s recording criteria under 29 CFR 1904.7 lay out six specific outcomes. If a work-related injury or illness results in any one of them, you record it:
- Death. Any work-related fatality is recordable regardless of the time between the injury and the death.
- Days away from work. If an employee misses one or more days because of the injury or illness, it’s recordable. You start counting the day after the injury occurred, not the day it happened.
- Restricted work or job transfer. If the employee can come to work but can’t perform one or more routine functions of their job, or gets reassigned to a different job, that counts. “Routine functions” means activities the employee performs at least once per week.
- Medical treatment beyond first aid. This is the trigger that causes the most confusion, and it has a very specific definition (covered in the next section).
- Loss of consciousness. Even briefly losing consciousness from a work-related event makes the case recordable.
- Significant injury or illness diagnosed by a physician or other licensed healthcare professional. This covers things like fractures, punctured eardrums, and chronic conditions that might not immediately require days away or restricted work but are still serious enough to record.
Only one of these triggers needs to apply. An employee who gets stitches but misses no work still has a recordable case because sutures are medical treatment beyond first aid.
Medical Treatment vs. First Aid
This is where most recordkeeping decisions are made, and OSHA doesn’t leave it open to interpretation. The agency provides a closed, exhaustive list of what counts as first aid. If the treatment isn’t on this list, it’s medical treatment, and the case is recordable.
Treatments that qualify as first aid (and are not recordable on their own):
- Non-prescription medications used at nonprescription strength
- Tetanus shots (but not hepatitis B, rabies, or other immunizations)
- Cleaning, flushing, or soaking surface wounds
- Bandages, gauze pads, butterfly bandages, or adhesive strips like Steri-Strips
- Hot or cold therapy
- Non-rigid supports like elastic bandages, wraps, or flexible back belts
- Temporary splints, slings, or neck collars used only during transport
- Drilling a fingernail or toenail to relieve pressure, or draining a blister
- Eye patches
- Removing foreign objects from the eye with irrigation or a cotton swab
- Removing splinters with tweezers, irrigation, or cotton swabs
- Finger guards
- Massage (but not physical therapy or chiropractic treatment)
- Drinking fluids for heat stress
That list is complete. No other treatments qualify as first aid for OSHA purposes. So if a doctor prescribes a medication, applies sutures or staples, uses a rigid brace or cast, orders physical therapy, or administers a vaccine other than tetanus, the case crosses the line into recordable territory. A common example: an employee sprains a wrist and gets an elastic wrap, that’s first aid. If the doctor prescribes a rigid wrist splint to immobilize the joint, it becomes recordable.
The key nuance with medications is strength, not availability. If a healthcare provider recommends that an employee take a nonprescription drug like ibuprofen at prescription-level doses, that recommendation alone counts as medical treatment.
The Incident Must Be Work-Related
An injury or illness is presumed work-related if it occurs in the work environment, which OSHA defines as any location where an employee is present as a condition of employment. But not every incident at work is automatically work-related. OSHA carves out specific exceptions:
- The employee was present as a member of the general public, not as a worker
- Symptoms surfaced at work but resulted entirely from a non-work event or exposure
- The injury happened during voluntary participation in a wellness program, fitness class, blood donation, or recreational activity
- The injury resulted from eating, drinking, or preparing personal food (choking on a sandwich at your desk, for example)
- The employee was doing personal tasks outside of assigned working hours
- The injury came 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 (though contagious diseases like tuberculosis or hepatitis A are recordable if contracted at work)
- The condition is a mental illness, unless the employee voluntarily provides a professional opinion stating it is work-related
If none of these exceptions apply and the injury or illness occurred in the work environment, it’s considered work-related for recordkeeping purposes.
Restricted Work and Job Transfers
Restricted work is one of the more frequently misunderstood triggers. It applies when a work-related injury or illness keeps an employee from performing their routine job functions or from working their full scheduled shift, even if they still come to work. It also applies when a healthcare provider recommends those restrictions, whether or not the employer actually enforces them.
Job transfer works similarly. If you assign an injured employee to a different job for even part of a day, that counts as a transfer and makes the case recordable. Both restricted work and job transfer cases go in the same column on the OSHA 300 Log, and you count the number of restricted or transferred days just as you would days away from work. The day of the injury itself doesn’t count toward the total.
New Cases vs. Recurrences
An injury or illness is a new case if the employee has never had a recorded injury of the same type to the same body part, or if they previously recovered completely and a new workplace event caused symptoms to return. “Recovered completely” means all signs and symptoms had disappeared.
Chronic occupational illnesses like asbestosis or silicosis are different. If symptoms recur or continue without a new workplace exposure, you only record the case once. But if a new exposure triggers a new episode, like an asthma attack caused by a workplace chemical, that episode gets recorded as a new case.
Special Recording Rules for Hearing Loss
Occupational hearing loss has its own criteria under 1904.10. A case is recordable when an employee’s audiogram shows a Standard Threshold Shift, defined as an average hearing loss of 10 decibels or more at 2000, 3000, and 4000 hertz compared to their baseline, and their total hearing level in the affected ear averages 25 decibels or more above audiometric zero at those same frequencies. Both conditions must be met. A shift in hearing that doesn’t cross the 25-decibel overall threshold isn’t recordable, even if the change from baseline is significant.
Recording vs. Reporting to OSHA
Recording and reporting are two separate obligations that often get confused. Recording means logging the incident on your OSHA 300 Log within 7 calendar days of learning it’s recordable. Reporting means directly notifying OSHA, and it only applies to the most severe outcomes.
You must report a work-related fatality to OSHA within 8 hours. For an in-patient hospitalization, amputation, or loss of an eye, you have 24 hours. These timelines start from when you learn the event occurred or when you learn it was work-related, whichever comes later. Every recordable case goes on the log, but only these four categories require a direct report to the agency.
Who Has to Keep Records
Most employers with more than 10 employees at any point in the previous calendar year must maintain OSHA injury and illness records. Employers with 10 or fewer employees are generally exempt from routine recordkeeping, as are businesses in certain low-hazard industries where the DART rate (days away, restricted, or transferred) falls below the national private sector average of 1.5 per 100 full-time workers.
Electronic submission requirements add another layer. Establishments with 250 or more employees must electronically submit data from their 300A annual summary form. Establishments with 20 to 249 employees in designated higher-hazard industries, including construction, manufacturing, warehousing, hospitals, nursing care facilities, trucking, and waste management, must also submit 300A data electronically. The full list of covered industries spans dozens of NAICS codes, so if you’re unsure whether your industry is included, OSHA publishes the complete list on its recordkeeping page.
Even employers who are otherwise exempt from routine recordkeeping must still report fatalities, hospitalizations, amputations, and eye losses directly to OSHA within the required timeframes. The exemption only covers the log, not the reporting obligation.