Is your incident OSHA-recordable?

Understanding OSHA recordability

Under 29 CFR Part 1904, most employers with more than 10 employees must record certain workplace injuries and illnesses on OSHA Forms 300, 300A, and 301. Knowing which incidents are "recordable" is the gate that decides whether a case enters your log — and missing one is a citable violation worth up to $16,550 per case.

Recordability comes down to three independent tests, all of which must pass:

1. Is it work-related?

Per 29 CFR 1904.5, an event or exposure in the work environment is presumed work-related if it either caused or contributed to the injury, or significantly aggravated a pre-existing condition. The work environment includes employer premises, locations where employees perform assigned duties, and employer-controlled vehicles during business use.

A small list of exceptions applies: voluntary wellness activities, personal tasks during break time, motor vehicle accidents in the employer parking lot during commute, common colds and flu (without work-related diagnosis), and intentional self-injury. Mental illness is only recordable when a healthcare professional concludes it is work-related.

2. Is it a new case?

Per 29 CFR 1904.6, a "new case" is the first time the employee has experienced this specific injury or illness, or a recurrence after they had fully recovered from a previously recorded case. Recurrences and continuations of existing cases do not generate a second Form 301 — but the existing record must be updated if outcomes change.

3. Does it meet the general recording criteria?

Per 29 CFR 1904.7, a work-related new case is recordable if it results in any one of the following:

• Death
• Days away from work (any amount)
• Restricted work activity or job transfer
• Medical treatment beyond first aid (OSHA provides a closed list of what counts as first aid in 1904.7(b)(5)(ii) — anything not on that list is medical treatment)
• Loss of consciousness
• A significant injury or illness diagnosed by a healthcare professional — including fractures, cracked bones, punctured eardrums, cancer, and chronic irreversible disease

Plus the special-category triggers: contaminated needlestick or sharps injuries (1904.8), tuberculosis exposure (1904.11), standard-threshold hearing loss (1904.10), and medical removal under specific OSHA standards (1904.9).

Reporting vs. recording — easy to confuse, important to separate

"Recording" and "reporting" mean different things in OSHA's framework. Recording is what you do internally — adding entries to Forms 300, 300A, and 301 and keeping them on file. Reporting is what you do externally — notifying OSHA directly. Most recordable cases are not reported. But:

• Fatalities must be reported to OSHA within 8 hours
• Hospitalizations, amputations, and loss of an eye must be reported within 24 hours

You can be late on your Form 301 even if you reported the incident on time. They are independent obligations.

Documenting your determination protects you in an audit

When the answer to "is this recordable?" is anything other than obviously yes, OSHA expects you to use reasonable judgment based on 29 CFR 1904 — and to document the basis for that judgment. A formal Recordability Determination Memo citing the specific CFR sections that informed your call is the kind of paper trail that turns a borderline case from a citation into a defensible record.