A workplace injury or illness becomes OSHA recordable when it is work-related and results in any one of six outcomes: 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 health care professional. Meeting just one of these triggers is enough. The trickiest part for most employers is distinguishing medical treatment from first aid, since OSHA draws a very specific line between the two.
The Six Recording Triggers
OSHA’s general recording criteria under Standard 1904.7 lay out six situations that make a work-related case recordable:
- Death
- Days away from work: any case where the employee misses one or more days beyond the day of 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 OSHA’s specific first aid list (more on this below)
- Loss of consciousness: even momentary, regardless of the cause
- Significant diagnosis: a physician or other licensed health care professional diagnoses a significant injury or illness, even if none of the other five triggers apply
That last category is the catch-all. A fractured rib discovered on an X-ray is recordable even if the worker doesn’t miss any time or receive treatment beyond first aid, because a licensed provider diagnosed a significant condition.
Medical Treatment vs. First Aid
This distinction trips up more recordkeeping decisions than anything else. OSHA maintains 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.
The following are all considered first aid under OSHA’s rules:
- Non-prescription medications used at nonprescription strength
- Tetanus shots (but not hepatitis B or rabies vaccines)
- Cleaning, flushing, or soaking surface wounds
- Bandages, gauze pads, butterfly bandages, or adhesive strips (but not sutures or staples)
- Hot or cold therapy
- Non-rigid supports like elastic bandages or wraps (but not rigid splints or braces with stays)
- Temporary immobilization devices used only during transport, such as a sling or neck collar
- Drilling a fingernail or toenail to relieve pressure, or draining a blister
- Eye patches
- Removing a foreign body from the eye with irrigation or a cotton swab
- Removing splinters with tweezers or irrigation
- Finger guards
- Massage (but not physical therapy or chiropractic treatment)
- Drinking fluids for heat stress
This list is complete. OSHA has stated that no other procedures qualify as first aid for recordkeeping purposes. So if a worker gets stitches instead of butterfly bandages, the case crosses over into medical treatment. If a doctor prescribes a medication at prescription strength, that’s medical treatment. If a worker is sent to physical therapy, that’s medical treatment. The line often comes down to a single clinical decision.
The Injury Must Be Work-Related
Before any of the recording triggers matter, the injury or illness has to be work-related. OSHA presumes work-relatedness if the event or exposure occurred in the work environment. But there are nine specific exceptions where an injury that happens at work still doesn’t count:
- The employee was on the premises 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 came from voluntary participation in a wellness program, fitness activity, or recreational event like a company softball game
- The injury resulted solely from eating, drinking, or preparing personal food (choking on a sandwich at your desk, for example)
- The employee was doing personal tasks unrelated to work, outside of assigned hours
- The injury resulted from personal grooming, self-medication for a non-work condition, or was intentionally self-inflicted
- A motor vehicle accident on a company parking lot or access road while commuting to or from work
- The common cold or flu (though contagious diseases like tuberculosis or hepatitis A are recordable if the employee was infected at work)
- Mental illness, unless the employee voluntarily provides an opinion from a qualified mental health professional stating the condition is work-related
Special Recording Rules
Needlestick and Sharps Injuries
Any work-related needlestick or cut from a sharp object contaminated with another person’s blood or other potentially infectious material is automatically recordable, regardless of whether it meets the general recording criteria. A cut from a clean object only needs to be recorded if it triggers one of the six standard criteria. If a worker is splashed with blood but not cut, the case is recordable only if it leads to a diagnosed bloodborne illness or meets the general criteria.
To protect privacy, the employee’s name is withheld from the OSHA 300 Log in needlestick cases.
Hearing Loss
Occupational hearing loss has its own threshold. A case is recordable when an employee’s audiogram shows a Standard Threshold Shift, defined as an average change of 10 decibels or more at 2000, 3000, and 4000 Hz in either ear compared to baseline, and the employee’s total hearing level in that same ear averages 25 decibels or more above audiometric zero at those frequencies. Both conditions must be met.
Counting Days Away and Restricted Work
When a recordable case involves days away from work or restricted duty, you count calendar days, not just scheduled workdays. Weekends and holidays count. The day of the injury itself is not counted. OSHA caps the count at 180 calendar days. If a worker is still away or on restricted duty after 180 days, you stop counting but keep the case on the log.
Restricted work means the employee cannot perform one or more of the routine functions of their job or cannot work a full shift. A job transfer to accommodate the injury also triggers this category.
Reporting Severe Events to OSHA
Recording an injury on your log and reporting it directly to OSHA are two different obligations. Most recordable injuries only need to be logged. But severe events have strict reporting deadlines:
- Fatalities: must be reported within 8 hours
- In-patient hospitalizations, amputations, or loss of an eye: must be reported within 24 hours
The fatality reporting window applies when a death occurs within 30 days of the work-related incident. For hospitalizations, amputations, and eye losses, the event must occur within 24 hours of the incident to trigger the reporting requirement. These reporting duties apply to all employers, including those otherwise exempt from routine recordkeeping.
Who Is Exempt From Recordkeeping
Two categories of employers are partially exempt from maintaining OSHA injury and illness logs. Establishments with 10 or fewer employees at all times during the previous calendar year don’t need to keep records. Certain industries classified under specific NAICS codes, generally lower-hazard sectors like retail, finance, and real estate, are also partially exempt.
Partially exempt means you don’t have to maintain the OSHA 300 Log, 301 Incident Report, or 300A Summary unless OSHA or the Bureau of Labor Statistics asks you to in writing. But even exempt employers must report fatalities, in-patient hospitalizations, amputations, and eye losses directly to OSHA within the required timeframes.
The Three Recordkeeping Forms
When an injury is recordable, it gets documented on three forms. The OSHA 300 Log is a running list of every recordable case at the establishment during the calendar year. Each case also gets its own OSHA 301 Incident Report, which captures details about how the injury happened. At the end of the year, the OSHA 300A Summary compiles totals from the log and must be posted in the workplace from February 1 through April 30 of the following year so employees can see the establishment’s injury and illness record.
All three forms must be retained for five years following the end of the calendar year they cover.