What Makes a Workplace Injury OSHA Recordable?

A workplace injury is OSHA recordable when it is work-related and results in at least one of six outcomes: death, days away from work, restricted work or a job transfer, loss of consciousness, medical treatment beyond first aid, or a significant diagnosis from a licensed healthcare professional. What makes a workplace injury OSHA recordable is that combination — the connection to the job on one side, and one of those six triggers on the other. Recording a case is not an admission of fault. It feeds the data OSHA and employers use to spot hazards.

Is the Injury Work-Related?

Every recordable case has to clear this threshold first. OSHA presumes an injury or illness is work-related if it results from an event or exposure in the work environment.¹ “Work environment” is read broadly and covers the employer’s establishment plus any location where the employee is present as a condition of employment. Fault doesn’t matter. A case also counts if work significantly aggravated a pre-existing condition, even when work didn’t cause it originally.

Exceptions That Break the Presumption

An injury that happens at the workplace is not work-related, and therefore not recordable, in these situations:¹

The employee was present as a member of the general public rather than as a worker.
Symptoms surfaced at work but resulted entirely from a non-work event or exposure.
The injury came from voluntary participation in a wellness program, fitness class, blood donation, or recreational activity like a company softball game.
The injury resulted solely from eating, drinking, or preparing food for personal consumption. Food poisoning from employer-provided food or contamination by workplace chemicals is still recordable.
The employee was doing something unrelated to the job, outside assigned working hours.
The injury came from personal grooming, self-medication for a non-work condition, or was intentionally self-inflicted.
A motor vehicle accident on a company parking lot or access road during the commute to or from work.
Common colds and flu. Contagious diseases like tuberculosis, hepatitis A, or plague are recordable if the employee was infected at work.
Mental illness, unless the employee voluntarily provides a statement from a qualified mental health professional linking the condition to work.

Travel and Home Offices

The normal commute doesn’t count as work. Business travel does, so long as the employee is engaged in work activities or acting in the employer’s interest. Two situations still break the connection during a trip: once a traveling employee checks into a hotel and establishes a temporary residence, injuries during what would be a normal commute between the hotel and the fixed job location are not recordable, and any personal detour from a reasonably direct travel route drops the work-relatedness during the detour.¹

For employees who telecommute, the injury has to happen while the employee is performing work and be directly connected to that work, not to the home environment.² Dropping a box of work documents on a foot qualifies. Tripping over the family dog on the way to answer a work call does not. Faulty home wiring that causes an electrocution is not work-related either.

The Six Recording Triggers

Once an injury or illness is work-related, it becomes recordable if any one of the following applies:³

Death. Any work-related fatality.
Days away from work. The employee misses at least one day after the day of injury. Count all calendar days the employee cannot work, including weekends and holidays. The day of the injury itself does not count. Employers may cap the count at 180 calendar days.
Restricted work or job transfer. The employee cannot perform all routine job functions or is moved to a different position.
Loss of consciousness. Any duration, however brief.
Medical treatment beyond first aid. Treatment that goes past OSHA’s specific first-aid list.
Significant diagnosis. A physician or licensed healthcare professional diagnoses cancer, a chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum. These are recorded at initial diagnosis even when no treatment or work restrictions have been recommended yet.

The 180-day cap is a practical relief. If an injury keeps someone out of work for months, the employer doesn’t have to count past 180 calendar days. Entering 180 satisfies the requirement.³

Medical Treatment or Just First Aid?

This is the trigger that trips up more employers than any other. OSHA maintains a specific, exhaustive list of what qualifies as first aid. If the treatment is on the list, the case is not recordable on treatment grounds alone. Anything not on the list counts as medical treatment, and the case becomes recordable.

The following are first aid under OSHA’s definition:³

Non-prescription medications at non-prescription strength
Tetanus shots (other immunizations, such as hepatitis B or rabies vaccines, do not qualify)
Cleaning, flushing, or soaking surface wounds
Wound coverings such as bandages, gauze pads, or butterfly closure strips
Hot or cold therapy
Non-rigid supports like elastic bandages or wraps
Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
Eye patches
Removing foreign bodies from the eye with irrigation or a cotton swab
Removing splinters or foreign material from areas other than the eye using irrigation, tweezers, cotton swabs, or other simple means
Finger guards
Massages
Drinking fluids to relieve heat stress
Using oxygen equipment on a one-time basis

Common treatments that cross into “medical” territory include prescription medications, stitches or staples, rigid splints or casts, and physical therapy or chiropractic care. A detail that surprises many employers: if a physician recommends medical treatment and the employee declines it, the case is still recordable. The recommendation alone is enough.

The medication rule has a wrinkle. Many drugs like ibuprofen are sold both over the counter and by prescription. The dividing line is the single-dose amount on the OTC label. If a doctor directs the employee to take more than the OTC per-dose amount, that’s prescription strength, and it’s medical treatment.⁴

Diagnostic procedures do not count as medical treatment. X-rays, blood tests, and visits solely for observation or counseling are not treatment for recordkeeping purposes.³

Cases With Their Own Rules

Hearing Loss

Occupational hearing loss uses different criteria than the six general triggers. A case is recordable only when an audiogram shows a Standard Threshold Shift — an average change of 10 decibels or more at 2000, 3000, and 4000 hertz compared to the employee’s baseline — and the overall hearing level in the affected ear averages 25 decibels or more above audiometric zero at those same frequencies.⁵ Both conditions must be met. A shift that doesn’t reach the 25-decibel overall threshold is not recordable.

Needlesticks and Sharps Injuries

All work-related needlestick injuries and cuts from sharp objects contaminated with another person’s blood or other potentially infectious material must be recorded, whether or not they meet any of the six general triggers.⁶ A cut from a clean object only needs to be recorded if it independently meets one of the general triggers, like medical treatment beyond first aid or days away from work.

Recording Is Not the Same as Reporting

Writing a case onto the OSHA 300 Log is one obligation. Calling OSHA about a severe incident is a separate one, with tight deadlines that apply no matter what size the employer is:⁷

A work-related fatality must be reported to OSHA within 8 hours.
A work-related in-patient hospitalization, amputation, or loss of an eye must be reported within 24 hours.

The clock starts when the employer or any of its agents learns of the event. If the work connection is discovered later, the deadline runs from that discovery.

Which Employers Have to Keep These Records

Most private-sector employers are covered by OSHA’s recordkeeping rules under 29 CFR Part 1904.⁸ Two partial exemptions narrow that duty. Companies with 10 or fewer employees at all times during the previous calendar year are exempt from routine recordkeeping, and establishments in certain lower-hazard industries (identified by NAICS code) are also exempt.⁹

Those exemptions only cover routine recordkeeping. Every employer under OSHA’s jurisdiction still has to report a work-related fatality, in-patient hospitalization, amputation, or loss of an eye, regardless of size or industry.¹⁰ Twenty-two states and territories operate their own OSHA-approved plans covering private and government workers, and seven more cover only state and local government employees.¹¹ State plans must be at least as protective as federal OSHA, so the criteria above apply as a floor, and some states add to them.

1
Occupational Safety and Health Administration. 29 CFR 1904.5 – Determination of Work-Relatedness
2
Occupational Safety and Health Administration. Determining Work-Relatedness for Injuries in the Home When Telecommuting
3
Occupational Safety and Health Administration. 29 CFR 1904.7 – General Recording Criteria
4
Occupational Safety and Health Administration. For Medications Such as Ibuprofen That Are Available in Both Prescription and Non-Prescription Form, What Is Considered to Be Prescription Strength
5
Occupational Safety and Health Administration. 29 CFR 1904.10 – Recording Criteria for Cases Involving Occupational Hearing Loss
6
Occupational Safety and Health Administration. 29 CFR 1904.8 – Recording Criteria for Needlestick and Sharps Injuries
7
Occupational Safety and Health Administration. 29 CFR 1904.39 – Reporting Fatalities, Hospitalizations, Amputations, and Losses of an Eye
8
Occupational Safety and Health Administration. Recordkeeping Requirements and Forms
9
Occupational Safety and Health Administration. 29 CFR 1904.1 – Partial Exemption for Employers With 10 or Fewer Employees
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Occupational Safety and Health Administration. Report a Fatality or Severe Injury
11
Occupational Safety and Health Administration. State Plans