Is it recordable? The OSHA recordkeeping decision, step by step

Short answerUnder 29 CFR 1904.4(a), you record a case on the OSHA 300 Log when three things are true: it is work-related (1904.5), it is a new case (1904.6), and it meets a general recording criterion in 1904.7 (death, days away, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness) or a special rule in 1904.8 to 1904.11. Enter it within seven calendar days of learning about it (1904.29(b)(3)).

Who has to keep OSHA injury and illness records

Part 1904 applies to most US private sector employers, with two partial exemptions. A company that had 10 or fewer employees at all times during the last calendar year does not keep routine records (1904.1(a)(1)), and the size test is based on peak employment across the whole company, not one site (1904.1(b)(1) and (b)(2)). Establishments in the low hazard industries listed in appendix A to subpart B are also partially exempt (1904.2(a)(1)). Both exemptions end if OSHA or the Bureau of Labor Statistics tells you in writing to keep records, and neither one excuses you from reporting severe injuries under 1904.39.

You record cases for everyone on your payroll, whether hourly, salaried, part-time, seasonal or migrant, and also for workers not on your payroll whom you supervise on a day-to-day basis (1904.31(a)). That includes temporary and leased workers (1904.31(b)(2)) and a contractor's employees when you, not the contractor, supervise their work day to day (1904.31(b)(3)). Each case goes on only one employer's log (1904.31(b)(4)). Self-employed people are not covered (1904.31(b)(1)).

State plan states must use the same rules as federal OSHA for deciding which cases are recordable and how they are recorded (1904.37(b)(1)). They may add to the reporting, retention and other provisions (1904.37(b)(2)).

Step 1: Is it work-related?

A case is work-related if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a preexisting injury or illness (1904.5(a)). Work-relatedness is presumed for anything that happens in the work environment unless one of the exceptions in 1904.5(b)(2) specifically applies. The work environment is the establishment and any other location where employees are working or are present as a condition of their employment, including the equipment and materials they use (1904.5(b)(1)). Company parking lots and sidewalks are part of the establishment, so a fall on ice while walking in before a shift is work-related even if the employee had not yet clocked in (OSHA interpretation, 15 January 2004).

The nine exceptions in 1904.5(b)(2). A case in the work environment is NOT work-related if it is:

(i) An injury or illness to someone present as a member of the general public rather than as an employee.
(ii) Signs or symptoms that surface at work but result solely from a non-work event or exposure outside the work environment.
(iii) Solely the result of voluntary participation in a wellness program or a medical, fitness or recreational activity, such as blood donation, a physical exam, a flu shot, an exercise class, racquetball or baseball.
(iv) Solely the result of eating, drinking or preparing food or drink for personal consumption. Food poisoning from food the employer supplied, or illness from food contaminated by a workplace contaminant such as lead, is work-related.
(v) Solely the result of personal tasks unrelated to the job, done at the establishment outside assigned working hours.
(vi) Solely the result of personal grooming, self medication for a non-work condition, or an intentionally self-inflicted injury.
(vii) Caused by a motor vehicle accident on a company parking lot or company access road while the employee is commuting to or from work. This covers motor vehicle accidents only, not slips, trips or falls in the lot.
(viii) The common cold or flu. Contagious diseases such as tuberculosis, brucellosis, hepatitis A or plague are work-related if the employee is infected at work.
(ix) A mental illness, unless the employee voluntarily gives you an opinion from a physician or other licensed health care professional with appropriate training stating that the mental illness is work-related.

Preexisting conditions, travel, home and the commute

A preexisting condition is one that resulted solely from a non-work event or exposure outside the work environment (1904.5(b)(5)). Work significantly aggravates it, making the case work-related, when a workplace event or exposure leads to death, loss of consciousness, days away, restricted work or job transfer, or medical treatment that would not otherwise have happened, or to a change in medical treatment (1904.5(b)(4)).

On travel status, a case is work-related if the employee was working in the interest of the employer at the time (1904.5(b)(6)). Once the employee checks into a hotel, it becomes a home away from home: activities there are judged like a non-traveling employee's, and the daily commute from the hotel to a fixed worksite is not work-related. A personal detour from a reasonably direct route is also not work-related.

For employees working at home, a case is work-related only if it happens while doing paid work and is directly related to that work rather than the general home setting (1904.5(b)(7)). Tripping over the family dog on the way to a work call is not work-related; dropping a box of work files on your foot is.

OSHA treats an injury during the normal commute from home to the worksite as not work-related, and the type of vehicle does not change that: a crash while commuting in a company vehicle was not recordable (OSHA interpretation, 13 April 2015).

Step 2: Is it a new case?

A case is new if the employee has not had a recorded injury or illness of the same type affecting the same part of the body, or had one but recovered completely (all signs and symptoms gone) before a workplace event or exposure brought the signs or symptoms back (1904.6(a)).

Chronic occupational illnesses whose signs may recur without further workplace exposure, such as occupational cancer, asbestosis, byssinosis and silicosis, are recorded only once (1904.6(b)(1)). An episode caused by a new workplace exposure, such as an occupational asthma attack, is a new case (1904.6(b)(2)). You do not have to ask a physician, but if you do, you must follow the recommendation (1904.6(b)(3)).

Step 3: The general recording criteria

A work-related new case is recordable if it results in any one of the following (1904.7(a) and (b)(1)):

Death (1904.7(b)(2)). Check column G and report to OSHA within 8 hours under 1904.39.
Days away from work (1904.7(b)(3)). Check column H and enter the calendar days in column K.
Restricted work or transfer to another job (1904.7(b)(4)). Check column I and enter the days in column L.
Medical treatment beyond first aid (1904.7(b)(5)). Check column J if there were no days away, restriction or transfer.
Loss of consciousness, for any length of time (1904.7(b)(6)).
A significant injury or illness diagnosed by a physician or other licensed health care professional (1904.7(b)(7)): cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum. These are recorded at diagnosis even if only first aid is given or no treatment is recommended.

Medical treatment versus first aid

Medical treatment means the management and care of a patient to combat disease or disorder (1904.7(b)(5)(i)). It does not include visits solely for observation or counseling, diagnostic procedures such as X-rays and blood tests (including prescription drugs used only for diagnosis, such as eye drops to dilate pupils), or anything on the first aid list.

Who gives the treatment does not matter. A first aid item is still first aid when a physician provides it, and treatment beyond first aid is medical treatment even when a non-professional provides it (1904.7(b)(5)(iv)). If a physician or other licensed health care professional recommends medical treatment, you record the case even if the employee does not follow the recommendation (1904.7(b)(5)(v)).

The complete first aid list, 1904.7(b)(5)(ii)

These 14 items are the only treatments that count as first aid. OSHA states that this is a complete list (1904.7(b)(5)(iii)), so any treatment not on it is medical treatment.

(A) Using a non-prescription medication at nonprescription strength. For a medication sold in both forms, a recommendation by a physician or other licensed health care professional to use the non-prescription medication at prescription strength is medical treatment. OSHA FAQ 7-8 says prescription strength is set by the single dose: anything greater than the single dose on the over-the-counter label counts.
(B) Administering tetanus immunizations. Other immunizations, such as hepatitis B vaccine or rabies vaccine, are medical treatment.
(C) Cleaning, flushing or soaking wounds on the surface of the skin.
(D) Using wound coverings such as bandages, adhesive bandages and gauze pads, or using butterfly bandages or Steri-Strips. Other wound closing devices, such as sutures and staples, are medical treatment.
(E) Using hot or cold therapy.
(F) Using any non-rigid means of support, such as elastic bandages, wraps and non-rigid back belts. Devices with rigid stays or other systems designed to immobilize parts of the body are medical treatment.
(G) Using temporary immobilization devices while transporting an accident victim, such as splints, slings, neck collars and back boards.
(H) Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister.
(I) Using eye patches.
(J) Removing foreign bodies from the eye using only irrigation or a cotton swab.
(K) Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means.
(L) Using finger guards.
(M) Using massages. Physical therapy and chiropractic treatment are medical treatment.
(N) Drinking fluids for relief of heat stress.

Counting days away, restricted work and job transfer

Days are counted the same way for all three outcomes (1904.7(b)(4)(xi)), and the rules below come from 1904.7(b)(3) and (b)(4).

Start counting the day after the injury or the onset of illness. The day of injury is never counted (1904.7(b)(3)(i)).
Count calendar days, not scheduled shifts. Weekends, holidays and vacation days are included if the employee could not have worked on them because of the injury (1904.7(b)(3)(iv)).
If the injury happens just before a weekend or scheduled time off, record it only if a physician or other licensed health care professional says the employee should not have worked, or should have worked restricted, during that time (1904.7(b)(3)(v) and (vi)).
If a physician recommends days away, record them even if the employee comes to work anyway (1904.7(b)(3)(ii)). If the physician releases the employee and the employee stays home, stop counting on the release date (1904.7(b)(3)(iii)).
You may cap the count at 180 calendar days of days away, restriction or transfer combined (1904.7(b)(3)(vii)).
If the employee leaves for a reason unrelated to the injury, such as retirement or a new job, you may stop counting. If they leave because of the injury, estimate the total (1904.7(b)(3)(viii)).
Record the case once, on the log for the year it happened, even if days run into the next year (1904.7(b)(3)(ix)).
Restricted work means the employee cannot do one or more routine functions (activities done at least once a week) or cannot work the full scheduled workday, whether you or a health care professional imposes it (1904.7(b)(4)(i) and (ii)). Producing less while doing every routine function is not restriction (1904.7(b)(4)(vi)).
A restriction or transfer that applies only to the day of injury is not recordable (1904.7(b)(4)(iii)). A partial shift on any later day counts as a restricted day (1904.7(b)(4)(v)).
Vague advice such as light duty: ask the professional whether the employee can do all routine functions and work the full shift. If you cannot find out, record it as restricted work (1904.7(b)(4)(vii)).

Special cases: needlesticks, medical removal, hearing loss and TB

Some cases are recordable under their own rule even when the general criteria are not met (1904.4(a)(3)).

Needlesticks and sharps (1904.8): record every work-related needlestick or cut from a sharp object contaminated with another person's blood or other potentially infectious material, as an injury, and do not enter the employee's name. Cuts from clean objects follow the general criteria (1904.8(b)(2)). A splash without a cut is recorded as an illness if it leads to a diagnosed bloodborne illness or meets 1904.7 (1904.8(b)(4)).
Medical removal (1904.9): record a case when an employee is medically removed under the medical surveillance requirements of an OSHA standard such as lead, cadmium, methylene chloride, formaldehyde or benzene, as days away or restricted work, and check the poisoning column if a chemical caused it. Voluntary removal before the standard's removal level is reached is not recordable (1904.9(b)(3)).
Hearing loss (1904.10): record when an audiogram shows a work-related Standard Threshold Shift (STS) AND the employee's total hearing level in the same ear is 25 dB or more above audiometric zero, both averaged at 2000, 3000 and 4000 Hz (1904.10(a)). An STS is an average change of 10 dB or more from baseline at those frequencies in one or both ears (1904.10(b)(1)). You may age-adjust when deciding the STS but not for the 25 dB test (1904.10(b)(3)). A retest within 30 days that does not confirm the STS means no recording; a confirmed STS is recorded within 7 days of the retest (1904.10(b)(4)). Check the hearing loss column (1904.10(b)(7)).
Tuberculosis (1904.11): record when an employee occupationally exposed to a known case of active TB develops a TB infection, shown by a positive skin test or diagnosis, in the respiratory condition column. A positive test at a pre-employment physical is not recorded (1904.11(b)(1)), and you may line out a case shown to come from household, community or other non-work exposure (1904.11(b)(2)).

Privacy concern cases

For a privacy concern case, write "privacy case" instead of the employee's name on the 300 Log and keep a separate confidential list of case numbers and names (1904.29(b)(6)). The list in 1904.29(b)(7) is complete (1904.29(b)(8)):

An injury or illness to an intimate body part or the reproductive system.
An injury or illness resulting from a sexual assault.
Mental illnesses.
HIV infection, hepatitis or tuberculosis.
Needlestick injuries and cuts from sharp objects contaminated with another person's blood or other potentially infectious material.
Other illnesses, if the employee voluntarily asks that their name not be entered.

Forms 300, 301 and 300A, and the posting dates

Use the OSHA 300 Log, the 301 Incident Report and the 300A Summary, or equivalent forms (1904.29(a)). Enter each recordable case on the 300 and complete a 301 within seven calendar days of learning about it (1904.29(b)(2) and (b)(3)). On the 300, check only one outcome column, the most serious: G death, H days away, I job transfer or restriction, or J other recordable cases. Enter day counts in K (away) and L (transfer or restriction), and mark the case type in column M: injury, skin disorder, respiratory condition, poisoning, hearing loss or all other illnesses (OSHA Form 300 instructions).

At year end, review the log, total it on the 300A (enter zeros if there were no cases), have a company executive certify it, and post it where employee notices are usually posted from February 1 to April 30 of the following year (1904.32). Keep the 300, the privacy case list, the 300A and the 301s for five years after the end of the year they cover, and keep the stored 300 Logs updated (1904.33). Give a copy of the 300 Log to an employee, former employee or representative who asks by the end of the next business day (1904.35(b)(2)(iii)).

Some establishments must also submit data electronically by March 2 each year: the 300A for those with 250 or more employees, or 20 to 249 employees in the industries in appendix A to subpart E, and the 300 and 301 for those with 100 or more employees in the industries in appendix B (1904.41(a) and (c)).

Severe injury reporting: 8 hours and 24 hours

Recording and reporting are separate duties. Under 1904.39(a), report to OSHA within 8 hours after a work-related fatality, and within 24 hours after a work-related in-patient hospitalization, amputation or loss of an eye. Report by phone or in person to the nearest Area Office, by phone to 1-800-321-OSHA (1-800-321-6742), or online at osha.gov (1904.39(a)(3)). An email, fax or answering machine message does not count (1904.39(b)(1)). All employers covered by the OSH Act must report, including those exempt from keeping records (1904.1(a)(1)).

Report a fatality only if it occurs within 30 days of the incident, and a hospitalization, amputation or eye loss only if it occurs within 24 hours of it (1904.39(b)(6)). If you learn of the event, or that it was work-related, later, the clock starts when you or your agent find out (1904.39(b)(7) and (b)(8)). In-patient hospitalization means formal admission for care or treatment; admission only for observation or diagnostic testing is not reportable (1904.39(b)(9) and (b)(10)). An amputation includes fingertip amputations with or without bone loss but not avulsions, deglovings or broken teeth (1904.39(b)(11)). Motor vehicle accidents on a public street outside a construction work zone, and events on commercial or public transportation, are not reported but are still recorded (1904.39(b)(3) and (b)(4)).

Sources and scope

This guide follows the text of 29 CFR Part 1904 as published in the eCFR (current to 8 October 2026), the OSHA 300 forms package, and OSHA's recordkeeping FAQs and letters of interpretation on osha.gov. It is a study and reference aid, not legal advice. For an unusual case, read the cited paragraph in full and check OSHA's interpretations or your state plan.

Test yourself: 20 scenarios

Pick an answer to see the ruling and the paragraph it comes from.

Score: 0 of 0 answered

A warehouse picker strains his wrist lifting a carton. The clinic physician tells him to take ibuprofen 800 mg three times a day and he returns to his normal job the same shift. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). A recommendation by a physician to use a non-prescription drug at prescription strength is medical treatment under 1904.7(b)(5)(ii)(A), and OSHA FAQ 7-8 treats any dose above the over-the-counter label's single dose as prescription strength. With no days away or restriction, it goes in column J (1904.7(b)(5)).

A packer cuts the back of her hand on a box cutter. At the emergency room a physician cleans the wound and closes it with Steri-Strips, and she returns to full duty the next day. Is it recordable, and in which column?

Answer: Not recordable, because wound closure strips are first aid. Butterfly bandages and Steri-Strips are first aid under 1904.7(b)(5)(ii)(D), and cleaning the wound is first aid under (C). Under 1904.7(b)(5)(iv) first aid stays first aid even when a physician provides it, and the day of injury is not a day away (1904.7(b)(3)(i)).

A maintenance mechanic slices his forearm on sheet metal. Urgent care closes the cut with three sutures, and he goes back to his regular duties the same afternoon. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). Sutures and staples are wound closing devices that 1904.7(b)(5)(ii)(D) names as medical treatment, unlike butterfly bandages or Steri-Strips. With no days away, restriction or transfer, the case is checked in column J (1904.7(b)(5)).

A roofer twists his ankle stepping off a ladder. EMTs apply a rigid splint for the ride to the ER, X-rays show no fracture, and the doctor diagnoses a sprain, wraps it with an elastic bandage and advises ice. He works his full job the next day. Is it recordable, and in which column?

Answer: Not recordable, because every treatment given was first aid. Temporary immobilization devices used while transporting a victim, including splints, are first aid under 1904.7(b)(5)(ii)(G), and X-rays are diagnostic procedures excluded from medical treatment by 1904.7(b)(5)(i)(B). The elastic wrap and ice are first aid under 1904.7(b)(5)(ii)(F) and (E).

An assembler reports low back pain after a shift of repetitive lifting. Her physician diagnoses a lumbar strain and orders six sessions of physical therapy, and she keeps working her regular job throughout. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). Massage is first aid, but 1904.7(b)(5)(ii)(M) states that physical therapy and chiropractic treatment are medical treatment. She stayed on full duty, so the case goes in column J (1904.7(b)(5)); a physician's recommendation is recorded even if she skips the sessions (1904.7(b)(5)(v)).

A grinder operator gets a metal particle in his eye. The site nurse flushes the eye with saline, then lifts the remaining particle off with a moist cotton swab, and he goes back to grinding with no restrictions. Is it recordable, and in which column?

Answer: Not recordable, because only irrigation and a swab were used. Removing a foreign body from the eye using only irrigation or a cotton swab is first aid under 1904.7(b)(5)(ii)(J). The nurse's professional status does not change that (1904.7(b)(5)(iv)), and PPE use has no bearing on recordability.

A welder's helper has a metal flake stuck in his eye that irrigation cannot dislodge. At the clinic a physician removes it with a fine needle under a slit lamp, and he returns to his normal job the next day. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). First aid covers eye foreign body removal using only irrigation or a cotton swab (1904.7(b)(5)(ii)(J)), and the first aid list is complete (1904.7(b)(5)(iii)), so removal with a needle is medical treatment. With no days away or restriction it goes in column J (1904.7(b)(5)).

A carpenter steps on a new, clean nail that punctures his boot sole. The nurse cleans the wound, covers it with a bandage and gives him a tetanus booster, and he finishes his shift. Is it recordable, and in which column?

Answer: Not recordable, because all of this care is first aid. Tetanus immunizations are first aid under 1904.7(b)(5)(ii)(B), as are cleaning a surface wound (C) and bandaging (D). The nail was not contaminated with another person's blood, so the sharps rule does not apply and the general criteria decide (1904.8(b)(2)).

A forklift driver bumps his chest on a rack. An X-ray at the clinic shows a cracked rib, but the doctor recommends only ice and over-the-counter pain relief at label dose, and he works his normal job. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). A fractured or cracked bone diagnosed by a physician or other licensed health care professional is a significant injury that must be recorded at diagnosis, even without medical treatment or restriction (1904.7(b)(7)). With no days away or restriction it is checked in column J.

A technician who works Monday to Friday sprains his knee at work on Wednesday. His physician tells him not to work until the following Monday, and he returns that Monday. Is it recordable, and in which column?

Answer: Recordable, column H, with 4 days away (Thursday to Sunday). Days away are counted from the day after the injury (1904.7(b)(3)(i)) in calendar days, including weekends he could not have worked because of the injury (1904.7(b)(3)(iv)). Thursday, Friday, Saturday and Sunday give 4 days in column K, with the case checked in column H.

At 10 a.m. a press operator bruises his hand. His supervisor moves him to inventory counting for the rest of that shift, he uses an ice pack, and the next day he runs the press as normal. Is it recordable, and in which column?

Answer: Not recordable, because the change applied only that day. A restriction or job transfer imposed only for the day the injury occurred is not recordable (1904.7(b)(4)(iii)), and partial days count only after the day of injury (1904.7(b)(4)(v)). Cold therapy is first aid under 1904.7(b)(5)(ii)(E).

A contractor's electrician works inside your plant, but your maintenance supervisor assigns his tasks and directs how he does them every day. He falls from a step stool and his physician keeps him off work for two days. Is it recordable on your log, and in which column?

Answer: Recordable on your log, column H (days away from work). You must record cases for workers not on your payroll whom you supervise day to day, including a contractor's employees (1904.31(a) and (b)(3)), and the case goes on only one log (1904.31(b)(4)). Two calendar days away puts it in column H (1904.7(b)(3)).

Driving into the company parking lot at the start of her shift, a clerk's car is hit by another employee's car. She has neck pain, receives prescription muscle relaxants and misses three days. Is it recordable, and in which column?

Answer: Not recordable, because the commuting exception applies. Under 1904.5(b)(2)(vii), an injury caused by a motor vehicle accident on a company parking lot or access road while the employee is commuting to or from work is not work-related. OSHA FAQ 5-9 applies this to both employees in a parking lot collision during the commute.

Twenty minutes before his shift, an accountant slips on ice walking from the company parking lot to the entrance and sprains his ankle. His doctor fits a rigid walking boot to immobilize it, and he works his full desk job. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). Company parking lots and sidewalks are part of the work environment, and OSHA's 15 January 2004 interpretation found a fall on ice before check-in work-related; the 1904.5(b)(2)(vii) exception covers only motor vehicle accidents. A rigid device designed to immobilize is medical treatment under 1904.7(b)(5)(ii)(F), so it goes in column J.

During her lunch break in the plant break room, a line worker bites into a sandwich she brought from home and cracks a molar. Her dentist fits a crown and she misses no work. Is it recordable, and in which column?

Answer: Not recordable, because it resulted solely from eating. An injury that results solely from eating, drinking or preparing food for personal consumption is not work-related under 1904.5(b)(2)(iv), even on the employer's premises. It would be work-related only if the food were contaminated by a workplace contaminant or was supplied by the employer and caused food poisoning.

On Monday morning an office worker tells her supervisor her lower back aches at her desk. She explains she strained it moving furniture at home on Saturday, and her doctor prescribes a muscle relaxant. Nothing at work contributed. Is it recordable, and in which column?

Answer: Not recordable, because the cause was solely outside work. Signs or symptoms that surface at work but result solely from a non-work event outside the work environment are not work-related under 1904.5(b)(2)(ii). With no work-relatedness, the medical treatment does not matter (1904.4(a)(1)).

A technician has a knee injury from weekend soccer that needed no treatment. After a week of repeated ladder climbing at work, the knee swells, and his physician, who attributes the flare to the climbing, prescribes a prescription anti-inflammatory. He stays on full duty. Is it recordable, and in which column?

Answer: Recordable, column J (other recordable cases). A workplace exposure significantly aggravates a preexisting condition when it leads to medical treatment that was not needed before (1904.5(b)(4)(iv)), which makes the case work-related under 1904.5(a). Prescription medication is medical treatment, and with full duty the case goes in column J.

A press operator's annual audiogram, compared with his baseline, shows an average shift of 12 dB at 2000, 3000 and 4000 Hz in his left ear. His average hearing level at those frequencies in that ear is 31 dB above audiometric zero, and a retest within 30 days confirms it. Is it recordable, and in which column?

Answer: Recordable, column J, with the hearing loss column checked. Under 1904.10(a) a work-related Standard Threshold Shift (an average 10 dB change from baseline at 2000, 3000 and 4000 Hz, 1904.10(b)(1)) is recordable when the same ear's total hearing level averages 25 dB or more above audiometric zero. Check the hearing loss column (1904.10(b)(7)); with no days away or restriction the outcome is column J.

A forklift driver's audiogram shows an average Standard Threshold Shift of 11 dB at 2000, 3000 and 4000 Hz in her right ear. Her average hearing level at those frequencies in that ear is 22 dB above audiometric zero. Is it recordable, and in which column?

Answer: Not recordable, because her hearing level is below 25 dB. 1904.10(a) requires both an STS and a total hearing level of 25 dB or more above audiometric zero, averaged at 2000, 3000 and 4000 Hz, in the same ear. At 22 dB the second test fails, and 1904.10(b)(3) does not allow age adjustment for the 25 dB test.

A phlebotomist sticks her finger with a needle she has just used to draw a patient's blood. She receives baseline blood tests and counseling only, tests negative, and finishes her shift. Is it recordable, and in which column?

Answer: Recordable, column J, as an injury entered as a privacy case. Under 1904.8(a), every work-related needlestick with a sharp contaminated by another person's blood is recorded as an injury, whatever the treatment, and the employee's name is not entered. It is a privacy concern case under 1904.29(b)(7)(v), and with no days away or restriction it falls in column J.

Questions people ask

What makes an injury recordable under OSHA?

A case is recordable when it is work-related under 1904.5, is a new case under 1904.6, and results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or other licensed health care professional (1904.7). Needlesticks, medical removal, hearing loss and TB have their own rules in 1904.8 to 1904.11.

Is a visit to the doctor or an X-ray recordable?

Not by itself. Visits solely for observation or counseling and diagnostic procedures such as X-rays and blood tests are not medical treatment (1904.7(b)(5)(i)). The case becomes recordable only if the visit leads to something on the recording criteria, such as prescription medication, sutures, physical therapy, restricted work or a diagnosed fracture.

Is a diagnosed fracture recordable if only first aid is given?

Yes. A fractured or cracked bone diagnosed by a physician or other licensed health care professional is a significant injury and must be recorded at diagnosis, even if no medical treatment or work restriction is recommended (1904.7(b)(7)). Cancer, chronic irreversible diseases and punctured eardrums are treated the same way.

Do weekends count as days away from work?

Yes, if the employee could not have worked on those days because of the injury. OSHA requires calendar days, regardless of whether the employee was scheduled to work (1904.7(b)(3)(iv)). Counting starts the day after the injury and may be capped at 180 days (1904.7(b)(3)(i) and (vii)).

Do I record injuries to temporary or contract workers?

Yes, if you supervise them on a day-to-day basis, even though they are not on your payroll (1904.31(a)). If the contractor or staffing agency provides the day-to-day supervision, it records the case instead. Each case is recorded on one log only (1904.31(b)(4)).

What is the difference between recordable and reportable?

Recordable means the case goes on your OSHA 300 Log within seven calendar days (1904.29(b)(3)). Reportable means you must also notify OSHA directly: within 8 hours for a work-related fatality and within 24 hours for an in-patient hospitalization, amputation or loss of an eye (1904.39(a)). Most recordable cases are never reportable.

Recordkeeping questions turn up on the ASP and CSP exams. Test yourself with scenario questions and full explanations.

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General guidance on OSHA recordkeeping (29 CFR 1904), not legal advice. Check the current regulation and OSHA interpretations for your case. HSE HUB by NeuraSafe.