Which Injuries Are OSHA Recordable? A Checklist for Contractors
The three tests OSHA uses to decide if an injury goes on the 300 log, the complete first aid list, restricted work, and 14 common jobsite cases worked through.
Quick answer
An injury or illness is OSHA recordable if it is work-related, is a new case, and leads to death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness, or is a significant diagnosed injury such as a fracture (29 CFR 1904.4 and 1904.7). First aid only cases are not recordable.
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What makes an injury recordable
29 CFR 1904.4 says a case goes on the OSHA 300 log only if it passes all three tests:
- It is work-related (29 CFR 1904.5).
- It is a new case (29 CFR 1904.6).
- It meets at least one recording criterion (29 CFR 1904.7), meaning it results in:
- death,
- days away from work,
- restricted work or transfer to another job,
- medical treatment beyond first aid,
- loss of consciousness, or
- a significant injury or illness diagnosed by a physician or other licensed health care professional: cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.
There are also a few specific cases that are always recorded when work-related: needlestick injuries and cuts from sharp objects contaminated with another person’s blood or other potentially infectious material (1904.8), medical removal under an OSHA health standard (1904.9), certain hearing loss found by audiogram (1904.10), and tuberculosis infection after exposure at work to a known active case (1904.11).
If a case fails any test, it does not go on the log. Most of the hard calls on a jobsite come down to one question: was the treatment first aid or medical treatment?
Test 1: is it work-related?
Under 1904.5(a), an injury or illness is work-related if an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition. Work-relatedness is presumed for anything that happens in the work environment, which includes the jobsite and other places employees work or are present as a condition of their job, plus the equipment and materials they use.
The rule lists the only exceptions (1904.5(b)(2)). The ones that come up most for contractors:
- The worker was there as a member of the public, not as an employee.
- Symptoms show up at work but result solely from something outside work (a back hurt moving furniture at home that flares up on the job).
- A car crash in a company parking lot or on a company access road while commuting.
- Eating, drinking or preparing food for personal use (but food poisoning from food the employer supplied is work-related).
- Personal tasks at the site outside working hours.
- Personal grooming, self-medication for a non-work condition, or an intentionally self-inflicted injury.
- The common cold or flu.
- Voluntary wellness or fitness activities.
- Mental illness, unless the employee voluntarily provides a health care professional’s opinion that it is work-related.
For crews on the road, 1904.5(b)(6) treats injuries during work travel as work-related, but once a worker checks into a hotel, time there is judged like time at home, and a personal side trip is not work-related.
Test 2: is it a new case?
A case is new if the worker has not had a recorded injury or illness of the same type to the same part of the body, or had one but fully recovered and a new event at work brought the symptoms back (1904.6(a)). A flare-up of a recorded case the worker never recovered from is not a new case; update the existing log entry instead.
Test 3: first aid or medical treatment?
This is the complete first aid list from 29 CFR 1904.7(b)(5)(ii). The rule says no other treatment counts as first aid (1904.7(b)(5)(iii)):
- Non-prescription medicine at non-prescription strength
- Tetanus shots (other shots, such as hepatitis B or rabies, are medical treatment)
- Cleaning, flushing or soaking wounds on the surface of the skin
- Wound coverings such as bandages and gauze pads, or butterfly bandages and Steri-Strips (stitches, staples and other wound closing devices are medical treatment)
- Hot or cold therapy
- Non-rigid support such as elastic bandages, wraps and non-rigid back belts (devices with rigid stays that immobilize a body part are medical treatment)
- Temporary immobilization while transporting an injured person (splints, slings, neck collars, back boards)
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Finger guards
- Massage (physical therapy and chiropractic treatment are medical treatment)
- Drinking fluids for relief of heat stress
Some things are neither first aid nor medical treatment, so on their own they do not make a case recordable (1904.7(b)(5)(i)): a visit to a doctor only for observation or counseling, and diagnostic tests such as x-rays and blood tests.
Three rules decide many cases:
- Who gives the treatment does not matter. A bandage from a doctor is still first aid; stitches from a foreman would still be medical treatment (1904.7(b)(5)(iv)).
- A recommendation counts. If a doctor recommends prescription medicine or another medical treatment and the worker does not follow it, the case is still recordable (1904.7(b)(5)(v)). For a medicine sold both ways, a recommendation to take it at prescription strength is medical treatment.
- Loss of consciousness is always recordable, however short (1904.7(b)(6)).
Restricted work and days away
Restricted work means the employer or a health care professional keeps the worker from doing one or more routine functions of their job, or from working a full day they would otherwise have worked (1904.7(b)(4)(i)). Routine functions are tasks the worker does at least once a week (1904.7(b)(4)(ii)).
- A restriction only for the rest of the day of the injury does not count (1904.7(b)(4)(iii)).
- A vague note such as “light duty” can be clarified with the doctor: can the worker do all routine functions and work a full shift? If either answer is no, or you cannot find out, the rule says to record it as restricted work (1904.7(b)(4)(vii)).
- Producing less while still doing every routine function is not restricted work (1904.7(b)(4)(vi)).
Days away start the day after the injury. A doctor’s recommendation to stay home counts even if the worker comes in (1904.7(b)(3)(ii)).
14 common jobsite cases
Each assumes the case is work-related and new, and nothing else happened beyond what is listed.
| Case | Recordable? | Why |
|---|---|---|
| Cut closed with Steri-Strips, back to work | No | Wound covering is first aid (item 4) |
| Cut closed with stitches or staples | Yes | Wound closing devices are medical treatment |
| Wood splinter removed with tweezers | No | First aid (item 11) |
| Metal particle flushed from the eye with water | No | First aid (item 10) |
| Metal particle removed from the eye with a tool by a doctor | Yes | Not on the first aid list, so medical treatment |
| Clinic visit, x-ray shows no fracture, told to ice it and take store-brand pain reliever at label strength | No | Diagnostic x-ray, cold therapy and non-prescription medicine |
| Doctor recommends prescription-strength medicine, worker never fills it | Yes | Recommended medical treatment counts |
| Cracked rib diagnosed, no treatment, no time off | Yes | Fractured or cracked bone is a significant diagnosed injury |
| Worker blacks out briefly after hitting their head | Yes | Loss of consciousness |
| Elastic wrap on a sprained ankle | No | Non-rigid support is first aid (item 6) |
| Rigid walking boot to immobilize a sprained ankle | Yes | Rigid devices that immobilize are medical treatment |
| Tetanus shot after stepping on a clean nail, wound cleaned | No | Tetanus shot and wound cleaning are first aid |
| Doctor bars lifting over 25 pounds for two weeks; the job involves heavier lifts every week | Yes | Restricted from a routine function |
| Worker hurt in a crash in the company parking lot on the drive in | No | Commuting exception in 1904.5(b)(2)(vii) |
Whose cases go on your log
Under 29 CFR 1904.31, you record cases for everyone on your payroll and for temp or staffing agency workers you supervise day to day. A subcontractor’s employees go on the sub’s log unless you supervise them day to day. Self-employed people and the owners or partners of a sole proprietorship or partnership are not counted.
Recordable is not the same as reportable
Recording means putting the case on your own log within 7 calendar days. Reporting means telling OSHA directly, which 29 CFR 1904.39 requires for a work-related death (within 8 hours) and for an in-patient hospitalization, amputation or loss of an eye (within 24 hours). Report by phone at 1-800-321-OSHA (1-800-321-6742), to the nearest area office, or on OSHA’s reporting page.
Once a case is recordable, it goes on the log and gets an OSHA 301 incident report.
Still not sure?
OSHA’s form package says that if you are not sure whether a case is recordable, you can call your local OSHA office for help. The OSHA recordkeeping page has answers to common questions, and the rule text is at 29 CFR 1904.5 and 1904.7. This page explains what the rule says; it is not legal advice.
Rules cited: 29 CFR 1904.4, 29 CFR 1904.5, 29 CFR 1904.6, 29 CFR 1904.7, 29 CFR 1904.8, 29 CFR 1904.31, 29 CFR 1904.39. Read the current text at osha.gov.
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