OSHA Recordable Injury or Illness: Criteria, Forms, and Penalties

An OSHA recordable injury or illness is a work-related case that causes any one of six outcomes: death, days away from work, restricted duty or a job transfer, medical treatment beyond first aid, loss of consciousness, or diagnosis of a significant condition such as cancer, a chronic irreversible disease, a broken bone, or a punctured eardrum. If the case is work-related and hits any single trigger, it goes on your log. Getting the call wrong carries real cost: recordkeeping violations run up to $16,550 each, and willful or repeated violations up to $165,514.¹

Is the Case Work-Related?

Recordability starts with a threshold question. OSHA presumes an injury or illness is work-related if it resulted from an event or exposure in the work environment, meaning any location where employees perform work, including company parking lots, break rooms, and job sites. The presumption covers pre-existing conditions too: if a workplace event or exposure significantly aggravates a condition the employee already had, the aggravation is recordable.²

A defined set of situations is carved out. You do not record an injury or illness that:

Happens during a normal commute to or from work, including in a company parking lot.
Results from personal tasks or grooming, like an employee cutting themselves shaving before a shift.
Comes from eating personal food, unless workplace chemicals contaminated it.
Involves voluntary wellness activities such as a company softball game, exercise class, or voluntary flu shot.
Is the common cold or flu (though contagious diseases like tuberculosis or hepatitis A contracted at work are recordable).
Is a mental illness, unless the employee voluntarily provides a diagnosis from a qualified mental health professional stating the condition is work-related.
Merely surfaces at work but stems entirely from a non-work cause.

These exceptions apply only when the non-work cause is the sole reason for the injury. If the work environment contributed at all, the case stays work-related.²

Travel and Remote Work

Employees on business travel are generally covered for the duration of the trip, as long as the injury happens while they are doing something in the employer’s interest. Once a traveling employee checks into a hotel, OSHA treats it as a “home away from home,” and the trip between that hotel and the work location counts as a commute, not a recordable event.³

For remote workers, an injury at home is recordable only if it happens while the employee is performing work for pay and is directly related to the work itself, not the home environment. Dropping a box of work documents on your foot is recordable. Tripping over the family dog while rushing to answer a work call is not. Getting shocked by faulty home wiring is not.⁴

The Six Recording Triggers

Once you have a work-related case, it becomes recordable if any one of these applies:⁵

Death. Any work-related fatality is always recordable.
Days away from work. If the employee misses at least one full day beyond the day of injury, the case is recordable. Counting starts the day after the incident.
Restricted work or job transfer. If the employee cannot perform all normal duties, cannot work a full scheduled shift, or is temporarily moved to a different job, the case is recordable.
Medical treatment beyond first aid. Explained in detail below.
Loss of consciousness. Any work-related incident that causes an employee to pass out is recordable, regardless of duration.
Significant diagnosed condition. A diagnosis by a physician or licensed healthcare professional of cancer, a chronic irreversible disease, a broken bone, or a punctured eardrum makes the case recordable at the time of diagnosis.

When counting days away or on restricted duty, cap the total at 180 calendar days. If the case exceeds that, enter 180 on the log and stop counting.⁶

Medical Treatment Versus First Aid

This is where most recordkeeping disputes happen. An injury treated only with first aid is not recordable unless it also triggers one of the other five criteria. The moment treatment crosses into medical treatment, the case becomes recordable regardless of who provides the care. A nurse at an on-site clinic administering prescription medication is medical treatment. A doctor applying a simple bandage is first aid. The type of treatment controls, not the credentials of the provider.⁶

What Qualifies as First Aid

OSHA lists first aid as a closed set. If a treatment is on the list, it is first aid. If it is not, it is medical treatment. First aid includes:

Over-the-counter medications used at their normal non-prescription dose
Bandages, gauze pads, butterfly closures, and similar wound coverings
Cleaning, flushing, or soaking surface wounds
Hot or cold therapy such as ice packs or heating pads
Non-rigid wraps and elastic bandages
Eye patches
Massages
Fluids to relieve heat stress
Oxygen administration
Removal of splinters or foreign material from the eye using irrigation or a cotton swab
Finger guards and toe protectors

What Crosses Into Medical Treatment

Anything not on that list is medical treatment. The cases that trip employers up:

Prescription medication. Any prescription drug, even a single dose, makes the case recordable. If a doctor recommends an over-the-counter medication at a prescription-strength dose, that also counts as medical treatment.⁶
Sutures, staples, or surgical glue. Butterfly bandages are first aid; anything that physically closes a wound beyond that is medical treatment.
Physical therapy or chiropractic care. Even a single session counts. There is no minimum visit threshold.⁶
Rigid braces and immobilization devices. Non-rigid elastic wraps are first aid. Anything with rigid stays or designed to immobilize a body part is medical treatment.

Cases That Are Always Recordable

A handful of conditions carry automatic recordability outside the general trigger analysis:

Needlestick and sharps injuries from any object contaminated with another person’s blood or infectious material, even if the injury itself seems minor.⁵
Medical removal required under an OSHA health standard, such as removal for lead exposure.
Work-related tuberculosis. If an employee is occupationally exposed to someone with active TB and later develops a positive skin test or is diagnosed with TB, the case goes on the log as a respiratory condition.⁵
Hearing loss. A standard threshold shift, meaning an average change of 10 decibels or more at 2000, 3000, and 4000 Hz, is recordable if the employee’s total hearing level in the affected ear also exceeds 25 dB above audiometric zero at those same frequencies.⁷

Who Has to Keep Records

Not every employer maintains OSHA injury and illness logs. Two partial exemptions reduce the routine recordkeeping burden, but neither eliminates the duty to report severe incidents.

Ten or Fewer Employees

If your company had ten or fewer employees at all times during the previous calendar year, you are exempt from routine OSHA recordkeeping. The count is based on peak headcount. Hitting eleven employees even briefly ends the exemption for the following year.⁸

Low-Risk Industries

Certain industries classified by NAICS code are exempt from routine recordkeeping regardless of size. The list skews toward office-based and retail sectors: law firms, accounting practices, banks, insurance carriers, software publishers, real estate brokerages, clothing stores, florists, and similar businesses.⁹ The full list appears in Appendix A to Subpart B of 29 CFR Part 1904.

What the Exemptions Do Not Cover

Even if you qualify for either exemption, you must still report fatalities within 8 hours and inpatient hospitalizations, amputations, or eye losses within 24 hours. OSHA or the Bureau of Labor Statistics can also require you to keep written records at any time, overriding your exempt status.⁸

Required Forms, Posting, and Retention

Employers who must keep records use three standardized OSHA forms:¹⁰

OSHA Form 300, the Log of Work-Related Injuries and Illnesses, a running log where each recordable case gets a one- or two-line entry throughout the year.
OSHA Form 301, the Injury and Illness Incident Report, a detailed report completed for each individual recordable case, covering circumstances, treatment, and employee information.
OSHA Form 300A, the Annual Summary, a year-end summary of the Form 300 data. Post it in a visible workplace location from February 1 through April 30 of the following year.

Each recordable case triggers entries on both the Form 300 log and a separate Form 301. Employers can use equivalent forms, such as a state workers’ compensation form, as long as they capture the same data fields.

For six categories of sensitive cases, employers must withhold the employee’s name from the Form 300 log and use a case number instead. Privacy concern cases include injuries to intimate body parts or the reproductive system, sexual assaults, mental illnesses, HIV or hepatitis infections, needlestick injuries involving contaminated materials, and any case where the employee voluntarily asks that their name be kept off the log.¹¹ The Form 301 still includes the employee’s name but is kept confidential.

All three forms must be kept for five years after the end of the calendar year they cover. During that window, update the Form 300 log if new recordable cases are discovered or if the classification of a previously recorded case changes. The Form 301 reports and Form 300A summary do not require updating.¹²

Electronic Submission to OSHA

Beyond keeping paper records, many employers must also submit injury and illness data electronically each year:

Establishments with 20 to 249 employees in designated high-hazard industries submit Form 300A summary data only. Covered sectors include construction, manufacturing, warehousing, hospitals, nursing care, waste management, and dozens of others with elevated injury rates.¹³
Establishments with 100 or more employees in industries listed in Appendix B to Subpart E submit the full set: Forms 300, 300A, and 301 data.¹⁴

The deadline is March 2 of the year following the data year. OSHA publishes the submitted data publicly.

Reporting Severe Incidents Directly to OSHA

Reporting is separate from recording. Recording means logging the case on your forms. Reporting means contacting OSHA directly, and it applies to every employer covered by the OSH Act, including those exempt from routine recordkeeping. The deadlines are short:

You can report by phone to the nearest OSHA area office, by calling the national hotline at 1-800-321-OSHA (6742), or through OSHA’s online reporting portal. Missing these windows is one of the most common and most avoidable violations employers face.

Penalties for Recordkeeping Violations

OSHA treats recordkeeping failures seriously. The maximum penalties, adjusted annually for inflation and effective January 2025, are:¹

Serious or other-than-serious violations: up to $16,550 per violation.
Failure to abate: up to $16,550 per day beyond the abatement deadline.
Willful or repeated violations: up to $165,514 per violation.

Each unrecorded case can be treated as a separate violation. An employer who failed to log ten recordable injuries faces potential fines for each one individually, and willful omissions escalate the math quickly. The figures adjust each January for inflation.

Where Employers Get This Wrong

A few patterns account for most recordkeeping errors. The first is treating the doctor’s visit as the trigger instead of the treatment provided. An employee who sees a physician but receives only first aid, such as a bandage and over-the-counter ibuprofen at a normal dose, does not have a recordable case even though a doctor was involved. On the other side, a company nurse who prescribes a course of antibiotics has just made the case recordable.

The second common mistake is assuming an injury has to be “serious” to be recordable. A small cut that gets two stitches is recordable. A badly bruised rib that only needs ice and rest is not. The test is treatment type, not severity of pain or drama of the incident.

The third is confusion about which employer records the case. Each employee must be linked to one of their employer’s establishments for recordkeeping purposes, and that employer records the injury on its own log even if the incident happened at someone else’s job site.¹⁵ On multi-employer worksites, the injured worker’s direct employer carries the recording obligation.

1
Occupational Safety and Health Administration. 2025 Annual Adjustments to OSHA Civil Penalties
2
Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness
3
Occupational Safety and Health Administration. Determining if Injuries and Illnesses Are Work-Related When Employees Commute From Home to Work and From a Hotel to a Worksite
4
Occupational Safety and Health Administration. 1904.5 – Determination of Work-Relatedness
5
eCFR. 29 CFR Part 1904 – Recording and Reporting Occupational Injuries and Illnesses
6
Occupational Safety and Health Administration. 1904.7 – General Recording Criteria
7
Occupational Safety and Health Administration. Recording Criteria for Cases Involving Occupational Hearing Loss
8
Occupational Safety and Health Administration. Partial Exemption for Employers With 10 or Fewer Employees
9
eCFR. 29 CFR Part 1904 Subpart B – Scope
10
Occupational Safety and Health Administration. 29 CFR 1904.29 – Forms
11
GovInfo. 29 CFR 1904.29 – Forms
12
Occupational Safety and Health Administration. 1904.33 – Retention and Updating
13
Occupational Safety and Health Administration. Establishments Required to Submit Electronically
14
Occupational Safety and Health Administration. ITA Coverage Application
15
Occupational Safety and Health Administration. Clarification of Multiple Business Establishments and Recordkeeping