A seizure at work is not automatically recordable under OSHA recordkeeping rules. Whether it belongs on the OSHA 300 Log turns on two questions: did the work environment cause or contribute to the episode, and did the outcome hit one of OSHA’s recording thresholds? Most seizures come from pre-existing conditions like epilepsy, so the seizure itself often falls outside the rules. But an injury sustained during the seizure — a fractured wrist from the fall, a laceration that needs sutures — is analyzed separately and can be recordable even when the seizure is not. That is where employers most often get it wrong.
The Two-Part Recordability Test
Every workplace injury or illness runs through the same filter. First, the case must be work-related under 29 CFR 1904.5. Second, it must meet at least one of the general recording criteria in 29 CFR 1904.7, such as loss of consciousness, medical treatment beyond first aid, or days away from work.1eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses Both tests must be satisfied. If either comes back negative, you don’t record.
Was the Seizure Itself Work-Related?
OSHA presumes that any injury or illness occurring in the work environment is work-related. The burden sits on the employer to identify a specific exception, not on the employee to prove a workplace connection.2Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness
The exception that matters here covers injuries or illnesses resulting solely from a non-work-related condition. An employee with epilepsy who has a seizure at their desk, with nothing about the job triggering the episode, is the classic case: the seizure itself is not work-related.2Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness
The exception disappears the moment the work environment plays a role. Chemical fume exposure, extreme heat, flashing lights from industrial equipment, or severe work-specific stress could all trigger or contribute to a seizure. When the job contributes, the seizure is work-related regardless of the underlying condition.
Significant Aggravation of a Pre-Existing Condition
Even a pre-existing seizure disorder can produce a work-related event if workplace conditions significantly aggravated it. OSHA defines significant aggravation as a workplace event or exposure that results in death, loss of consciousness, days away from work, restricted duty, job transfer, or medical treatment that wasn’t needed before.2Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness If working conditions pushed a controlled seizure disorder into an episode requiring hospitalization, the aggravation itself establishes the work connection.
Injuries from the Seizure Are a Separate Analysis
Here is the piece employers miss most often. The seizure is one event. Any injury caused by the seizure is a different event, and each one gets its own recordability analysis.
OSHA addressed this directly in an interpretation letter. An employee with no prior epilepsy diagnosis had a seizure while sitting at his desk, fell from the chair, and cut his head badly enough to require sutures. OSHA ruled the laceration recordable: the injury resulted from an event in the work environment, and sutures exceed first aid. Recording the injury does not imply employer fault; it reflects that the physical harm happened at work.3Occupational Safety and Health Administration. Injuries Resulting From Epileptic Seizures at Work Are Recordable
So even after you correctly conclude the seizure itself is not work-related, walk through every injury that happened during or after it. A fractured wrist from hitting machinery, a burn from falling onto a hot surface, a concussion from striking the floor — each is a separate injury in the work environment with its own recording analysis.
Which Outcomes Trigger Recording
Once work-relatedness is established for either the seizure or a secondary injury, the case is recordable if it results in any of the following:4Occupational Safety and Health Administration. 1904.7 – General Recording Criteria
- Death
- Days away from work
- Restricted work or job transfer
- Medical treatment beyond first aid
- Loss of consciousness
For seizures, loss of consciousness is the most common trigger. OSHA requires recording any work-related event that causes unconsciousness, however briefly.4Occupational Safety and Health Administration. 1904.7 – General Recording Criteria There is no minimum duration.
Not every seizure involves unconsciousness. Focal aware seizures affect movement or sensation without loss of awareness. A work-related seizure of that type that produces no days away, no restricted duty, and no treatment beyond first aid would not meet recording criteria.
First Aid Versus Medical Treatment
The line between first aid and medical treatment often decides borderline cases. OSHA maintains a specific list of what counts as first aid, and anything not on the list is medical treatment.4Occupational Safety and Health Administration. 1904.7 – General Recording Criteria For seizure scenarios, the useful contrasts:
- First aid (not recordable on its own): non-prescription medication at non-prescription strength, bandages and gauze pads, cold packs, non-rigid supports such as elastic wraps, and temporary splints used during transport.
- Medical treatment (triggers recording): prescription medication, sutures or staples, rigid immobilization devices, and physical therapy.
Prescription anti-seizure medication administered after a work-related episode is medical treatment beyond first aid, and that alone makes the case recordable. A doctor visit solely for observation or diagnostic testing, though, does not cross the medical-treatment threshold.
When the Employee Refuses Treatment
An employee’s refusal to follow a doctor’s recommendation does not let the employer off the hook. If a health care professional recommends treatment beyond first aid for a work-related injury, the case is recordable whether or not the employee follows through.4Occupational Safety and Health Administration. 1904.7 – General Recording Criteria The recommendation itself establishes that the injury met the threshold.
Privacy Protections on the 300 Log
Seizure disorders are sensitive medical information, and the annual OSHA 300A summary is posted where all employees can see it. For designated “privacy concern cases,” the employer must not enter the employee’s name on the 300 Log; instead, they write “privacy case” in the name field and keep a separate confidential list linking case numbers to names.5Occupational Safety and Health Administration. 1904.29 – Forms
The designated categories are mental illnesses, injuries to intimate body parts, sexual assault cases, needlestick injuries, and HIV, hepatitis, or tuberculosis. A seizure disorder is not automatically on that list. But any employee may voluntarily ask that their name be withheld, and the employer must honor the request.5Occupational Safety and Health Administration. 1904.29 – Forms Given how the summary is displayed, it’s worth raising this option with the affected employee.
The Separate Duty to Report Directly to OSHA
Logging a case on the 300 form is routine recordkeeping. Reporting directly to OSHA is a separate, faster obligation for the most severe outcomes. Employers must report a work-related fatality within eight hours and a work-related in-patient hospitalization, amputation, or loss of an eye within 24 hours.1eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses Reports go to the nearest OSHA Area Office by phone or in person, to the toll-free hotline at 1-800-321-6742, or through the online portal at osha.gov.
A seizure alone does not trigger this reporting duty. It becomes relevant only when a secondary injury produces one of those severe outcomes. If a seizure causes a fall that results in a skull fracture requiring overnight admission, the 24-hour clock starts. There’s an important limit: the in-patient hospitalization must occur within 24 hours of the workplace incident. If the employee goes home and is admitted two days later, direct reporting is not required, though the case must still be recorded on the 300 Log if recordkeeping applies.1eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
Hospitalization solely for observation or diagnostic testing does not count as in-patient hospitalization for reporting purposes. The employee must be formally admitted to the in-patient service of a hospital for care or treatment.1eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
Deadlines, Exemptions, and Penalties
The Seven-Day Recording Window
When a case is recordable, the employer has seven calendar days from the date they learn of the injury or illness to enter it on the 300 Log and complete the OSHA 301 Incident Report or an equivalent form.5Occupational Safety and Health Administration. 1904.29 – Forms The clock starts when the employer receives information making the case recordable, not necessarily when the incident happens. If an employee goes to a doctor three days after a fall and only then receives prescription medication, the seven days begin when the employer learns about the prescription.
Employers Exempt From Routine Recordkeeping
Not every employer has to keep a 300 Log. Companies with 10 or fewer employees during the previous calendar year are partially exempt; they don’t maintain injury and illness logs unless OSHA or the Bureau of Labor Statistics specifically directs them to in writing.6Occupational Safety and Health Administration. 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees Certain low-hazard industries identified by NAICS code also get a partial exemption.7Occupational Safety and Health Administration. 1904 Subpart B Appendix A – Partially Exempt Industries
The exemptions cover only routine recordkeeping. Every employer covered by the OSH Act still has to report fatalities, in-patient hospitalizations, amputations, and eye losses under the timelines above.6Occupational Safety and Health Administration. 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees
Penalties
Recordkeeping violations are treated seriously. As of the annual adjustment effective January 2025, a single serious or other-than-serious violation carries a maximum penalty of $16,550. Willful or repeated violations can reach $165,514 per violation.8Occupational Safety and Health Administration. OSHA Penalties These figures adjust for inflation each January. Each unrecorded case can be a separate violation, so a pattern of missed entries adds up quickly.
One Note on Obligations Beyond Recordkeeping
OSHA recordkeeping is a separate track from the Americans with Disabilities Act. Epilepsy and other seizure disorders are disabilities under the ADA, and the EEOC has its own guidance on fitness-for-duty exams, reasonable accommodations, and when an employer may restrict duties.9U.S. Equal Employment Opportunity Commission. Epilepsy in the Workplace and the ADA Deciding whether a case belongs on the 300 Log does not answer those questions, and answering them does not change what belongs on the Log.