OSHA Recordkeeping 101: When Is an Injury Recordable?

The Recording Decision Tree

Every time a work-related injury or illness occurs, you face a critical question: does this go on the OSHA 300 log? Getting it wrong in either direction creates risk: under-recording can be cited, and over-recording inflates your TRIR.

At a glance: An injury is recordable if it's work-related, a new case, and meets a criterion — death, days away, restriction/transfer, medical treatment beyond first aid, loss of consciousness, or an HCP-diagnosed significant injury (1904.7). The first-aid-vs-medical line is where most errors happen (a butterfly bandage = first aid; one suture = recordable). Record within 7 calendar days. An OSHA injury is recordable if it is work-related, a new case, and results in death, days away from work, restricted work, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury — and it must be logged within seven calendar days.

---

Step 1: Is It Work-Related?

Under 29 CFR 1904.5(a), an injury is work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing one. The work environment (1904.5(b)(1)) includes:

• The employer's premises
• Any location where the employee performs work-related activities
• Travel between work locations

Exceptions: in the work environment, but not work-related (1904.5(b)(2))

• Symptoms surfacing at work from a non-work condition
• Voluntary participation in wellness programs
• Intentionally self-inflicted injuries
• Personal grooming, self-medication, eating/drinking (non-contaminated)
• Motor vehicle accidents on a company parking lot or access road during the commute

These are five of the nine exceptions; the other four (members of the public, personal tasks outside working hours, colds and flu, and mental illness unless a health care professional's opinion ties it to work) are in the 9 work-relatedness exceptions.

---

Step 2: Is It a New Case? (1904.6)

A recordable injury has to be a new case — not the continuation of one you already logged. Under 1904.6(a), a case is new if either:

• The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body; or
• The employee had such a case before, recovered completely (all signs and symptoms gone), and an event or exposure in the work environment made the signs or symptoms reappear.

So a worker who fully recovered from a back strain in March and strains the same back on a new lift in July has a new case — log it again. A worker whose March strain never fully resolved and simply flares up is the same case — you update the original entry, you don't open a second one.

Chronic conditions and recurring symptoms

For a chronic work-related illness whose symptoms recur even without further exposure — the standard names occupational cancer, asbestosis, byssinosis, and silicosis — you record the case only once (1904.6(b)). But where a workplace event triggers the recurrence — the standard's example is an episode of occupational asthma (1904.6(b)(2)) — each episode is a new case.

Aggravation of a pre-existing condition (1904.5(b)(4))

A condition the worker brought to the job becomes recordable only if a workplace event or exposure significantly aggravated it. Under 1904.5(b)(4), "significantly aggravated" means the work event caused any of the following that would not otherwise have occurred: death; loss of consciousness; one or more days away, restricted, or transferred; or medical treatment where none was needed before — or a change in the treatment already being given. If the pre-existing condition would have produced the same result on its own, it is not recordable.

If you ask a doctor, follow the answer

You are not required to consult a physician or other licensed health care professional to make the new-case call. But if you do, 1904.6(b)(3) says you must follow their recommendation — and where you receive conflicting opinions, you decide which is the most authoritative (best documented, best reasoned).

---

Step 3: Does It Meet a Recording Criterion?

Under 1904.7(b)(1), a work-related new case is recordable if it results in ANY of these:

---

The First Aid vs. Medical Treatment Line

First aid treatments are NOT recordable on their own, even if the injury is work-related. First aid is the complete list in 1904.7(b)(5)(ii); anything else is medical treatment, apart from observation, counseling, and diagnostic procedures (1904.7(b)(5)(i)).

First Aid (NOT recordable):

• Wound cleaning, flushing, soaking
• Bandages, butterfly bandages, Steri-Strips
• Non-prescription medications at non-prescription strength
• Tetanus immunizations
• Eye patches, eye flushing
• Hot/cold therapy
• Temporary immobilization devices during transport
• Drilling a fingernail to relieve pressure
• Removing splinters with tweezers

Medical Treatment (RECORDABLE):

• Sutures (stitches) — any number
• Prescription medications — including prescription-strength ibuprofen
• Physical therapy or chiropractic treatment
• Wound closing devices such as sutures and staples (1904.7(b)(5)(ii)(D))

The Tricky Cases

---

The 7-Day Rule

You must enter a recordable case on the 300 Log and the 301 within 7 calendar days of receiving information that it occurred (1904.29(b)(3)).

Common mistakes:

• Waiting for the employee to "see if it gets better"
• Recording only when the worker files a claim
• Backdating an entry after an inspection, which turns a late entry into a false record (29 U.S.C. 666(g))

---

How to Count the Days (1904.7(b)(3))

When a case involves days away from work or restricted duty, the number you enter isn't a judgment call — 1904.7(b)(3) sets the mechanics:

• Count calendar days, not scheduled workdays (1904.7(b)(3)(iv)). Weekends, holidays, and days the employee wasn't scheduled still count if the worker was unable to work or was restricted.
• Start the day after the injury (1904.7(b)(3)(i)). The day of the incident is the injury date, not day one — counting begins the next calendar day.
• You may cap the count at 180 days (1904.7(b)(3)(vii)). Once a case reaches 180 calendar days away, restricted, or transferred — in any combination — you can stop counting and enter 180. You never have to track one case past that.
• Away vs. restricted (1904.7(b)(4)): a case can involve both. Count the days-away period in column K and the restricted/transfer period in column L; the day the worker returns to normal duty ends the count and isn't itself counted.

---

Special Recording Rules (MSDs, Hearing Loss, Sharps)

Musculoskeletal Disorders (MSDs)

Record like any other injury, under the general criteria of 1904.7: if it results in medical treatment beyond first aid, days away, or restricted work.

Hearing Loss

Recordable under 1904.10(a) if:

• Work-related AND
• An STS (Standard Threshold Shift) of 10 dB or more averaged at 2000, 3000, and 4000 Hz relative to baseline AND
• The total hearing level reaches 25 dB or more above audiometric zero, averaged at 2000, 3000, and 4000 Hz, in the same ear

Needle Sticks and Sharps

Record every work-related needlestick or cut from a sharp object contaminated with another person's blood or other potentially infectious material (1904.8(a)), whether or not an infection follows. Enter it on the 300 Log as a privacy case, without the employee's name; the name goes on your separate confidential list (1904.29(b)(6)).

---

Recordkeeping Penalties

---

The standard, tools & related reading

• The standard: Recordkeeping — 29 CFR 1904
• On the job: OSHA Recordability Decision Tree · OSHA 300A Auto-Filler · OSHA Deadline Calendar
• Related guides: OSHA Forms 300, 300A & 301 — Complete Guide · 300A Posting vs Electronic Submission (2026) · 30-Year Record Retention (1910.1020)
• 2026 OSHA penalty schedule · penalties by state

An accurate log is also the clearest report card your safety program gets.

Sources & verification (read on the eCFR, October 5, 2026): 29 CFR 1904.5, 1904.6, 1904.7, 1904.8, 1904.10, 1904.29, 1904.39 and 1904.41; penalty maximums per 29 CFR 1903.15(d); 29 U.S.C. 666(g). General guidance, not legal advice.