Recordkeeping (29 CFR Part 1904, all covered employers)

General Recording Criteria for Cases

Verified vs OSHA sources · 2026-10-05

29 CFR 1904.7

29 CFR 1904.7 sets the general recording criteria: the "what happened?" prong of recordability. A work-related, new case is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness, or if it is a significant injury or illness diagnosed by a physician or other licensed health care professional.

29 CFR 1904.7 at a glance

Recordable if it results in: Death, days away, restricted work/transfer, medical treatment beyond first aid, or loss of consciousness
Plus: Any significant injury/illness diagnosed by a physician or licensed HCP
First aid: An exhaustive list in §1904.7(b)(5)(ii): anything beyond it is medical treatment
Day counts: Calendar days, capped at 180 for days away + restricted combined
Max penalty (2026): Other-than-serious $16,550; willful $165,514
The #1 confusion: The first-aid list is closed: "minor" treatment off the list is still recordable

What 29 CFR 1904.7 requires (plain English)

29 CFR 1904.7 defines the general recording criteria: once a case is work-related (§1904.5) and a new case (§1904.6), it becomes recordable if it results in any of a defined set of outcomes (death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness) or if it is a significant work-related injury or illness diagnosed by a physician or other licensed health care professional.

The rule then defines each outcome precisely. "Medical treatment beyond first aid" is defined by exclusion: §1904.7(b)(5)(ii) gives an exhaustive list of what counts as first aid (for example, non-prescription medication at non-prescription strength, tetanus shots, cleaning and bandaging, hot/cold therapy, temporary splints for transport). Any treatment not on that list is medical treatment, and the case is recordable. Days away and restricted-work days are counted in calendar days, and the combined count for a single case is capped at 180 days.

Because these criteria also drive the severity measures (the total recordable case rate and the DART (days away, restricted, or transferred) rate) 1904.7 is the section employers most often get wrong, usually by classifying medical treatment as first aid or by mishandling day counts. The criteria are objective, and the first-aid list, not the treater's opinion, controls.

The regulatory text

“You must consider an injury or illness to meet the general recording criteria, and therefore to be recordable, if it results in any of the following: death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. You must also consider a case to meet the general recording criteria if it involves a significant injury or illness diagnosed by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.”

29 CFR 1904.7(a)

Key facts about 29 CFR 1904.7

A work-related new case is recordable if it results in death, days away, restricted work/transfer, medical treatment beyond first aid, or loss of consciousness (1904.7(a)).
A significant diagnosed injury/illness is recordable even without those outcomes.
"First aid" is an exhaustive list in §1904.7(b)(5)(ii); anything beyond it is medical treatment.
Prescription medication (even a single dose) is medical treatment, not first aid.
Days away and restricted-work days are counted in calendar days.
The combined day count for one case is capped at 180 days.
These criteria drive the total recordable case rate and the DART rate.

Scope: who 29 CFR 1904.7 applies to

Regulatory framework: Recordkeeping (29 CFR Part 1904, all covered employers)
Citation reference: 29 CFR 1904.7
Enforcement status: In force and enforced
Jurisdiction: Federal OSHA (29 State-Plan jurisdictions may be stricter)

State-Plan states (e.g. California, Washington, Michigan) operate OSHA-approved programs that must be at least as effective as federal OSHA and frequently impose higher penalties or additional requirements. Confirm the rule as adopted in your state.

Key requirements of 29 CFR 1904.7

#	Employer obligation
1	Distinguish first aid from medical treatment
2	Record restricted work/job transfer cases
3	Count lost workdays correctly
4	Record needle sticks and sharps injuries
5	Apply hearing loss recording criteria (STS of 10 dB)

Summarized from the text of 29 CFR 1904.7. Always read the full regulation for the binding language.

Common General Recording Criteria violations

Deficiencies OSHA cites under 29 CFR 1904.7 include the ones below, in no particular order. Distinct deficiencies can be cited as separate items, and each serious item carries up to $16,550 (2026). Broader per-instance stacking exists but is a discretionary, case-by-case OSHA enforcement policy, not an automatic multiplier.

Classifying medical treatment (e.g., prescription meds, sutures) as first aid (1904.7(b)(5)).
Under-counting days away from work or restricted-work days (1904.7(b)(3)/(4)).
Not recording a restricted-work or job-transfer case (1904.7(b)(4)).
Failing to record a significant diagnosed injury/illness (1904.7(b)(7)).
Not capping the combined day count at 180 or otherwise miscounting (1904.7(b)(3)(vii)).

The first-aid list is closed: a treatment not on it is recordable, however minor it seems

The most consequential recordkeeping error is treating "minor" care as first aid when it is not on OSHA's list. Under 1904.7, first aid is defined by an EXHAUSTIVE list in §1904.7(b)(5)(ii), for example, non-prescription medicine at non-prescription dose, tetanus immunizations, cleaning and bandaging, hot or cold therapy, non-rigid means of support, and temporary immobilization for transport. If the treatment given is NOT on that list (prescription medication, sutures, a prescription-strength dose, physical therapy) it is medical treatment beyond first aid, and the case is recordable, no matter how small it feels. The list, not the clinician's characterization or the employer's judgment, decides.

What OSHA inspectors look for

A compliance officer focuses on the first-aid vs. medical-treatment line and on days-away and restricted-work counts. Downgrading medical treatment to "first aid," under-counting days away, or failing to record restricted-work cases are the classic 1904.7 findings.

Example: how a violation is cited

A worker gets prescription-strength medication and two days off after a strain. The employer logs it as "first aid, no days," but prescription medication is medical treatment and the time off is days away. OSHA corrects the entry and cites the recordkeeping error, up to $16,550.

Illustrative example, not a specific OSHA case.

General Recording Criteria compliance checklist

Use this to evaluate your compliance with 29 CFR 1904.7. Each item is a key requirement OSHA may verify during an inspection.

For each work-related new case, check it against the 1904.7 outcomes.
Compare the treatment given against the exhaustive first-aid list in §1904.7(b)(5)(ii).
Count days away and restricted-work days in calendar days; cap the combined total at 180.
Record restricted-work and job-transfer cases, not just lost-time cases.
Record significant diagnosed conditions even without the standard outcomes.
Base decisions on the criteria and the first-aid list, not on how "minor" a case seems.

2026 penalties for 29 CFR 1904.7

Maximums set by 29 CFR 1903.15(d). 2026 amounts unchanged from 2025 (no CPI adjustment; OMB M-26-11). Not an increase. The 2025 OSHA penalty levels remain in effect for 2026; OSHA made no inflation adjustment for 2026. 29 CFR 1903.15 identifies January 15, 2025 as the effective reference for these amounts, while OSHA's public penalties page currently references penalties assessed after Jan. 15, 2026.

Violation type	Minimum	Maximum	When it applies
Serious	$1,085	$16,550	Substantial probability of death or serious physical harm.
Other-Than-Serious	$0	$16,550	Relates to safety/health but unlikely to cause death or serious harm.
Willful	$11,823	$165,514	Intentional, knowing, or voluntary disregard of the requirement.
Repeated	$4,256	$165,514	A substantially similar violation cited within the last 5 years.
Failure to Abate	None	$16,550/day	up to $16,550 per day; total capped at 30x the daily amount (FOM Ch.6)

Misapplied 1904.7 criteria (first-aid downgrades, miscounted days) are cited as other-than-serious, up to $16,550 per case; willful under-recording reaches $165,514.

Maximums and the willful minimum are set by 29 CFR 1903.15(d); the serious and repeated minimums are OSHA policy floors from its annual penalty adjustment memo. OSHA applies gravity-based and size, good-faith and history reductions (FOM CPL 02-00-164 Ch.6). Estimates only, not legal advice.

The business case for General Recording Criteria compliance

1904.7 is where most recordkeeping disputes actually live, because the criteria decide not just whether a case is recorded but how severe it looks: days away and restricted-work days feed the DART rate that OSHA and customers watch. The first-aid list is exhaustive: if a treatment is not on it, the case is recordable. Small classification choices move the numbers a lot.

Free compliance tools for 29 CFR 1904.7

OSHA Recordability Decision Tree OSHA 300A Auto-Filler OSHA 301 Incident Form

General Recording Criteria penalties by state

Penalties and enforcement vary by state. State-Plan states may impose higher penalties and additional requirements beyond federal 29 CFR 1904.7.

Alabama Arkansas Colorado Connecticut Delaware District of Columbia

View all 50 states + DC →

Frequently asked questions about 29 CFR 1904.7

What makes a case recordable under 1904.7?

A work-related, new case is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. It is also recordable if it is a significant injury or illness diagnosed by a physician or other licensed health care professional, even without those outcomes.

What counts as first aid vs. medical treatment?

First aid is an exhaustive list in §1904.7(b)(5)(ii): things like non-prescription medication at non-prescription strength, tetanus shots, cleaning and bandaging wounds, hot/cold therapy, non-rigid supports, and temporary splints for transport. Any treatment NOT on that list is medical treatment beyond first aid, which makes the case recordable. Prescription medication and sutures, for instance, are medical treatment.

How do I count days away from work?

Count calendar days, not just scheduled workdays, beginning the day after the injury. Record days away and restricted-work days separately on the 300 Log. The combined total of days away plus restricted or transferred days for a single case is capped at 180 days: you stop counting once you reach 180.

Is a case with only restricted duty recordable?

Yes. Restricted work or transfer to another job is one of the general recording criteria in 1904.7. If a work-related injury keeps an employee from doing one or more routine job functions, or from working a full shift, or leads to a job transfer, the case is recordable and the restricted days are counted, even if the worker never missed a full day.

Regulatory history of 29 CFR 1904.7

The 1904.7 criteria and the exhaustive first-aid list took effect January 1, 2002 (66 FR 5916). Defining first aid as a closed list was a deliberate change from the older, more subjective approach: it made recordability turn on whether a specific treatment appears on the list, reducing case-by-case disputes about what counts as "more than first aid."

Related glossary terms

Key terms that appear in 29 CFR 1904.7, each with a full plain-English explainer.

Recordable Injury National Emphasis Program Industrial Hygiene Job Hazard Analysis

Related guides & articles

OSHA Recordkeeping: When Is an Injury Recordable?OSHA Forms 300, 300A & 301 Recordkeeping Guide

Related OSHA standards

29 CFR 1910.1020

Exposure & Medical Records

29 CFR 1904.4

Recording Criteria

29 CFR 1904.5

Work-Relatedness

29 CFR 1904.29

OSHA Injury Forms

Primary sources

OSHA figures on this page are imported from HazComFast's verified regulatory module (verified 2026-10-05 against eCFR, OSHA.gov, and the Federal Register).

This page is an educational summary, not legal advice. OSHA standards and penalty amounts change; confirm requirements against the current regulation and your applicable State-Plan before acting.

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OSHA does not give advance notice of inspections (29 CFR 1903.6). Get the binder in order before the opening conference, not during it.

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