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OSHA Recordable Checker: Is This Injury Recordable?

Check a work-related injury or illness against the general recording criteria of 29 CFR 1904.7, including OSHA's complete 14-item first-aid list.

Checked against its source on ; next check .

Work-relatedness and new case
General recording criteria (29 CFR 1904.7(b))
First aid given, if any (29 CFR 1904.7(b)(5)(ii))
Medical treatment

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This checker takes one injury or illness through the general recording criteria of 29 CFR 1904.7 and tells you whether it belongs on the OSHA 300 Log, and in which column. Tick what happened to the employee, and the answer updates as you go. The page address keeps your answers, so you can send the result to someone else.

The first two boxes are questions, not decisions. The checker doesn't work out whether a case is work-related or whether it's a new case: it takes your answer as given. Those two calls belong to 29 CFR 1904.5 and 29 CFR 1904.6, and you should read them before you tick either box.

Worked example: a cut that's cleaned, bandaged, then stitched

This is an example, not a real case. An employee cuts a hand on the job. Someone cleans the cut and puts a bandage on it, and that's all the care it gets. The checker opens with this case: the work-related and new-case boxes ticked, plus first aid (C) and (D), and nothing else. The answer is Not recordable: cleaning a surface wound and covering it are both on OSHA's first-aid list, and no general criterion is met.

Now say the cut needs stitches. Stitches aren't on the list, so tick Any other treatment not on the first-aid list above. The answer changes to Recordable, and the column is J: Other recordable cases, under 29 CFR 1904.7(b)(5). The first-aid item for wound coverings spells out the line between the two in its own parenthesis: "other wound closing devices such as sutures, staples, etc., are considered medical treatment". A butterfly bandage or Steri-Strip on the same cut would have kept it first aid.

Worked example: a sprain and three days of light duty

Also an example. An employee sprains an ankle, and the doctor sends them back to work on light duty for three days, with no climbing ladders, which is part of their usual job every week. That restriction keeps them from a routine job function, so it's restricted work. Untick the two first-aid boxes and tick Restricted work or a job transfer after the day of injury. The checker says Recordable, in column I: Job transfer or restriction, and reminds you how to count the days.

The count doesn't include the day it happened. For days away, the rule answers that directly: "No, you begin counting days away on the day after the injury occurred or the illness began." Paragraph (b)(4)(xi) has you count restricted days the same way. A restriction that covers only the day of the injury isn't recorded at all: "you do not have to record restricted work or job transfers if you, or the physician or other licensed health care professional, impose the restriction or transfer only for the day on which the injury occurred or the illness began".

Light duty is a vague instruction, and paragraph (b)(4)(vii) says what to do with it. You may ask the physician whether the employee can do all of their routine job functions and work their full normal shift. Two yes answers mean the case isn't a restricted-work case. A no to either means it is. If you can't get an answer from the physician who recommended the restriction, record the case as restricted work.

The six general recording criteria

Under 1904.7, a work-related new case is recordable if it results in any one of these:

  • death, paragraph (b)(2);
  • days away from work, paragraph (b)(3);
  • restricted work or transfer to another job, paragraph (b)(4);
  • medical treatment beyond first aid, paragraph (b)(5);
  • loss of consciousness, paragraph (b)(6);
  • a significant injury or illness diagnosed by a physician or other licensed health care professional, paragraph (b)(7).

Loss of consciousness has no minimum. The case is recorded "regardless of the length of time the employee remains unconscious". Paragraph (b)(7) names the significant diagnoses: "Work-related cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded under the general criteria at the time of diagnosis by a physician or other licensed health care professional."

A recommendation from a physician or other licensed health care professional counts even when the employee ignores it. If the employee is told to stay home and comes in anyway, you still record the recommended days away, paragraph (b)(3)(ii). If treatment is recommended and the employee skips it, you still record the case, paragraph (b)(5)(v).

First aid is a closed list

The regulation lists fourteen first-aid treatments, and nothing else qualifies. Asked whether any other procedures are included in first aid, paragraph (b)(5)(iii) answers: "No, this is a complete list of all treatments considered first aid for part 1904 purposes." It doesn't matter who gives it, either: "Even when these treatments are provided by a physician or other licensed health care professional, they are considered first aid for the purposes of part 1904."

Some things aren't medical treatment in the first place. Under paragraph (b)(5)(i), a visit to a physician or other licensed health care professional only for observation or counseling doesn't count, and neither do diagnostic procedures such as x-rays and blood tests. That's why the checker's treatment box leaves them out. All fourteen first-aid items are in the table below the checker, word for word from the regulation.

Which column, and how to count days

A case goes in one outcome column only. The instructions with the forms say to "Classify the case by recording the most serious outcome of the case, with column G (Death) being the most serious and column J (Other recordable cases) being the least serious." So a case with both days away and restricted work goes in column H, and the checker picks that column for you when you tick more than one box.

Long cases have a ceiling. The regulation says "entering 180 in the total days away column will be considered adequate", and the forms put it this way: "You may stop counting days of restricted work activity or days away from work once the total of either or the combination of both reaches 180 days."

For three worked cases that each land in a different column, and for the significant-diagnosis conditions that don't depend on treatment at all, see what counts as a recordable injury.

A death goes in column G. Paragraph (b)(2) adds a second duty to the check mark in that column: "You must also report any work-related fatality to OSHA within eight (8) hours, as required by § 1904.39."

Reporting to OSHA is a separate duty

The log is a record you keep. Reporting is different: it means contacting OSHA directly, soon after the event, and it applies to four kinds of event, not only deaths. Recording a case never counts as reporting it, and reporting it never excuses you from recording it. Paragraph (a) of 29 CFR 1904.39 sets the two deadlines:

  • "Within eight (8) hours after the death of any employee as a result of a work-related incident, you must report the fatality to the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor."
  • "Within twenty-four (24) hours after the in-patient hospitalization of one or more employees or an employee's amputation or an employee's loss of an eye, as a result of a work-related incident, you must report the in-patient hospitalization, amputation, or loss of an eye to OSHA."

The checker has no box for a hospitalization, an amputation or a lost eye, so it can't tell you whether a case must be reported. What it does is show a reminder of both deadlines with every recordable result. The rest of 1904.39 fills in the details, in its own question-and-answer form:

  • How. Paragraph (a)(3) allows three methods: by telephone or in person to the nearest OSHA Area Office, by telephone to OSHA's toll-free number, 1-800-321-OSHA (1-800-321-6742), or through the reporting application on OSHA's website.
  • Events that come later. A death is reportable only if it happens within 30 days of the incident, and a hospitalization, amputation or loss of an eye only if it happens within 24 hours of it, paragraph (b)(6). Either way, the case still goes on the log if you're required to keep one.
  • News that arrives late. If you learn of the event after it happens, or learn only later that it was work-related, the same 8 or 24 hours run from when you or your agent find out, paragraphs (b)(7) and (b)(8).
  • What counts as a hospitalization. It must be a formal admission to a hospital or clinic's in-patient service for care or treatment, paragraph (b)(9). In the regulation's words, "you do not have to report an in-patient hospitalization that involves only observation or diagnostic testing", paragraph (b)(10).
  • Road and transit accidents. A motor vehicle accident on a public street or highway outside a construction work zone, or an event on a commercial or public transportation system, doesn't have to be reported, but it still has to be recorded if you're required to keep records, paragraphs (b)(3) and (b)(4).

Small employers aren't let off. 29 CFR 1904.1(a)(1) lets a company with 10 or fewer employees at all times last year skip the log, unless OSHA or BLS tells it in writing to keep one, then adds that "all employers covered by the OSH Act must report to OSHA any work-related incident that results in a fatality, the in-patient hospitalization of one or more employees, an employee amputation, or an employee loss of an eye."

Do we have to submit electronically?

Not every employer that keeps the log sends it to OSHA every year. Under 29 CFR 1904.41(b)(1), only three kinds of establishment submit routinely, and paragraph (c) sets the deadline: they "must submit all of the required information by March 2 of the year after the calendar year covered by the form(s)".

Employees at any time last yearIndustryWhat to submit
20-249Listed in Appendix A to Subpart EForm 300A
250 or moreAny industry that must keep recordsForm 300A
100 or moreListed in Appendix B to Subpart EForms 300 and 301, as well as Form 300A

The two industry lists are in Appendices A and B to Subpart E of Part 1904, the subpart that 1904.41 belongs to.

The headcount is people, not full-time equivalents. Paragraph (b)(2) says "each individual employed in the establishment at any time during the calendar year counts as one employee, including full-time, part-time, seasonal, and temporary workers".

Partially exempt employers don't submit routinely. That covers a company with 10 or fewer employees at all times last year (1904.1) and establishments in the industries listed in Appendix A to Subpart B (1904.2). Under 1904.41(b)(6), they only have to submit if OSHA tells them in writing that it will collect their data.

As for how, OSHA's forms page says: "Covered establishments must submit their annual 300A, 300, and 301 data to the Injury Tracking Application (ITA)."

What this checker doesn't cover

  • The specific recording criteria in 29 CFR 1904.8 to 1904.12. The forms package names them as a separate route to a recordable case, and this page doesn't go further than that.
  • Deciding whether a case is work-related (1904.5) or new (1904.6). You answer those.
  • Deciding whether an event must be reported under 1904.39. The result reminds you of the 8-hour and 24-hour deadlines, but only you know whether there was a death, an in-patient admission, an amputation or a lost eye.
  • Privacy concern cases, differences under State Plans, and when to go back and update an entry from an earlier year.

If a case doesn't fit neatly, ask OSHA or your OSHA area office before you rely on this checker's answer.

First aid under 29 CFR 1904.7(b)(5)(ii): OSHA's complete list
ItemTreatment
(A)Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes)
(B)Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment)
(C)Cleaning, flushing or soaking wounds on the surface of the skin
(D)Using wound coverings such as bandages, Band-Aids™, gauze pads, etc.; or using butterfly bandages or Steri-Strips™ (other wound closing devices such as sutures, staples, etc., are considered medical treatment)
(E)Using hot or cold therapy
(F)Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)
(G)Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)
(H)Drilling of 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 or chiropractic treatment are considered medical treatment for recordkeeping purposes)
(N)Drinking fluids for relief of heat stress
Sources (7)

Updated