How OSHA recordability actually works
OSHA injury and illness recording is a three-part test under 29 CFR 1904 (29 CFR 1904.4(a)). A case lands on the OSHA 300 Log only when all three are true:
- Work-related — an event or exposure in the work environment caused, contributed to, or significantly aggravated the injury/illness, and no 29 CFR 1904.5(b)(2) exception applies.
- A new case — not a continuation of an already-recorded case to the same body part (29 CFR 1904.6).
- Meets a recording criterion — either a general criterion (death, days away, restricted work/transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis, 29 CFR 1904.7) or one of the additional criteria for specific cases (29 CFR 1904.8 contaminated needlesticks and sharps, 29 CFR 1904.9 medical removal, 29 CFR 1904.10 hearing loss, 29 CFR 1904.11 tuberculosis).
The decision tree above walks these in order and stops the moment the answer is settled — so a non-work-related case never reaches the criteria questions, and the first criterion that's met determines the column and deadline.
The six general recording criteria
Once a case is work-related and new, any one of these makes it recordable (29 CFR 1904.7(b)):
| Criterion | When it's recordable | CFR |
|---|---|---|
| Death | Always recordable; report fatalities within 8 hours | 29 CFR 1904.7(b)(1) |
| Days away from work | Actual or physician-recommended; count calendar days, cap at 180 | 29 CFR 1904.7(b)(3) |
| Restricted work or transfer | Can't do routine functions / full day; cap at 180 | 29 CFR 1904.7(b)(4) |
| Medical treatment beyond first aid | Anything not on the 14-item first-aid list | 29 CFR 1904.7(b)(5) |
| Loss of consciousness | Any duration, always recordable | 29 CFR 1904.7(b)(6) |
| Significant diagnosis | Cancer, chronic irreversible disease, fracture, punctured eardrum | 29 CFR 1904.7(b)(7) |
Recording vs. reporting — don't confuse them
Recording means entering a case on your own 300 Log within 7 calendar days (29 CFR 1904.29(b)(3)) and keeping the records 5 years (29 CFR 1904.33). Reporting means notifying OSHA directly: a fatality within 8 hours, and an in-patient hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39). Every employer must report severe events even when partially exempt from routine recordkeeping.
Worked examples
1) Carpenter gets stitches. A finger laceration on the jobsite needs three sutures. Work-related? Yes (1904.5). New case? Yes. Sutures are medical treatment beyond first aid (1904.7(b)(5)), so it is RECORDABLE — column J, no days away. Record within 7 days; no severe-event report required.
2) Worker tweaks a back lifting at the company gym. The strain happened during a voluntary fitness activity, which is a 1904.5(b)(2) work-relatedness exception. The case is NOT recordable — document internally only.
3) Electrician hospitalized overnight after a shock. Work-related, new case, and admitted as an in-patient → RECORDABLE (days away/column H if off work). Because it's an in-patient hospitalization within 24 hours of the incident, it is also reportable to OSHA within 24 hours (29 CFR 1904.39).
What to do once you have a determination
- Recordable? Enter it on the OSHA 300 Log within 7 calendar days (29 CFR 1904.29(b)(3)) and complete a 301 incident report within the same 7 days; the annual 300A summary is prepared after the year ends (1904.32). Mark the correct column (H = days away, I = restricted/transfer, J = other).
- Severe event? Report the fatality (8 hr) or hospitalization/amputation/ eye loss (24 hr) to OSHA first — the reporting clock is independent of the 7-day record.
- Close call? Get the treating physician/LHCP's opinion in writing and re-run this tree; recordability can change if the case later develops days away, restriction, or treatment.
- Keep the paper trail. Save the PDF determination record from this tool with your 301 to show your reasoning 5 years later.
Frequently asked questions
What is the difference between first aid and medical treatment?
First aid is the closed 14-item list in 29 CFR 1904.7(b)(5)(ii): non-prescription medications at non-prescription (OTC) strength, tetanus immunizations, cleaning/flushing/soaking surface wounds, wound coverings (bandages, butterfly closures, Steri-Strips), hot/cold therapy, non-rigid supports (elastic bandages, wraps), temporary immobilization for transport, drilling a fingernail or draining a blister, eye patches, removing foreign bodies from the eye with irrigation or a cotton swab, removing splinters/foreign material from areas other than the eye with tweezers/cotton swabs, finger guards, massages, and drinking fluids for heat stress. Treatment beyond this list (sutures, prescriptions, physical therapy, surgery) is medical treatment, which makes a work-related case recordable. Two other things are not medical treatment either: a visit to a physician solely for observation or counseling, and diagnostic procedures such as x-rays and blood tests (1904.7(b)(5)(i)). The degree of a burn does not decide recordability; what counts is the outcome (days away, restriction, or medical treatment).
Do I have to record every workplace injury?
No. A case is recordable only when it is (1) work-related under 1904.5, (2) a new case under 1904.6, AND (3) meets one or more of the general recording criteria of 1904.7 (death, days away from work, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis) or the additional criteria of 1904.8 through 1904.11 (contaminated needlestick or sharps injuries, medical removal, hearing loss, tuberculosis). Miss all of them and the case stays off the 300 Log.
Are small employers exempt from OSHA recordkeeping?
Employers with 10 or fewer employees at all times during the previous calendar year are partially exempt from routinely keeping the 300/300A/301 (29 CFR 1904.1), and establishments in certain lower-hazard industries are partially exempt by NAICS (1904.2 / Appendix A). BUT every employer — regardless of size or industry — must still REPORT a fatality within 8 hours and an in-patient hospitalization, amputation, or loss of an eye within 24 hours (1904.39).
How is a recordable case different from a reportable event?
Recording means entering a case on your own OSHA 300 Log within 7 calendar days (1904.29). Reporting means notifying OSHA directly: a fatality within 8 hours, and an in-patient hospitalization, amputation, or loss of an eye within 24 hours (1904.39). A single severe event is often both recordable AND reportable, but many recordable cases (e.g., a sutured laceration) are not reportable at all.
How long must I keep OSHA 300 Logs and 301 forms?
Keep the OSHA 300 Log, the annual 300A summary, the privacy-case list, and the 301 Incident Reports for 5 years following the end of the calendar year the records cover (29 CFR 1904.33), and update the 300 Log during that period if you learn of new recordable cases or changes. The 300A summary must be posted in the workplace from February 1 to April 30 of the year after the records cover.
Is this decision tree legal advice?
No. It mirrors the recording logic of 29 CFR 1904 (work-related → new case → general criteria) to help you make a fast, defensible first determination, but it cannot capture every fact pattern, the special criteria in 1904.8–1904.11 (needlesticks, medical removal, hearing loss, TB), or your State-Plan's rules. When a case is close, consult the treating physician/LHCP and your OSHA Area Office.
Sources & verification
- eCFR — 29 CFR Part 1904 (Recording and Reporting Occupational Injuries and Illnesses)
- OSHA Injury & Illness Recordkeeping & Reporting
CFR citations verified 2026-10-05 against eCFR Title 29 Part 1904. This tool mirrors the 1904 recording logic to help you make a fast, defensible determination — it is not legal advice. Special criteria in 1904.8–1904.11 (needlesticks, medical removal, hearing loss, TB) and State-Plan rules may apply.
OSHA 300A auto-filler →Training record generator →29 CFR 1904 standard →When is an injury recordable? →