A recordable injury is a work-related injury or illness that meets OSHA's general recording criteria and must be entered on the OSHA 300 Log. Under 29 CFR 1904.7, a case is recordable if it results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed injury or illness.
Recordable injuries and illnesses are the basis for widely used safety metrics such as the total recordable incident rate. Getting the recordability decision right matters for compliance and for the accuracy of every number built on top of it.
What Is a Recordable Injury?
OSHA's recordkeeping rule, 29 CFR Part 1904, requires covered employers to record certain work-related injuries and illnesses. A case is recordable when three conditions are met:
- It is an injury or illness, meaning an abnormal condition or disorder.
- It is work-related, meaning an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition (29 CFR 1904.5).
- It is a new case that meets one or more of the general recording criteria (29 CFR 1904.6 and 1904.7).
The general recording criteria in 29 CFR 1904.7 are:
- Death
- Days away from work
- Restricted work or transfer to another job
- Medical treatment beyond first aid
- Loss of consciousness
- A significant injury or illness diagnosed by a physician or other licensed health care professional, such as cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum
Although the common phrase is "recordable injury," the same rules apply to occupational illnesses.
Additional Specific Recording Criteria
Part 1904 also includes specific criteria for certain cases, including needlestick and sharps injuries involving contamination with another person's blood or other potentially infectious material (1904.8), medical removal under an OSHA standard (1904.9), occupational hearing loss meeting the standard threshold shift criteria (1904.10) and work-related tuberculosis infection (1904.11).
Medical Treatment vs. First Aid
The most common recordability question is whether care counts as medical treatment or first aid. OSHA defines first aid using a closed list of 14 items in 1904.7(b)(5)(ii). If a treatment is not on the list, it is generally considered medical treatment. First aid includes:
- Using a nonprescription medication at nonprescription strength
- Administering tetanus immunizations
- Cleaning, flushing or soaking surface wounds
- Using wound coverings such as bandages, gauze pads or butterfly bandages and Steri-Strips
- Using hot or cold therapy
- Using non-rigid means of support, such as elastic bandages, wraps and non-rigid back belts
- Using temporary immobilization devices while transporting an accident victim
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Using eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means
- Using finger guards
- Using massages
- Drinking fluids for relief of heat stress
Common examples of medical treatment include sutures or surgical glue, prescription medications (or nonprescription drugs recommended at prescription strength), rigid splints or casts used for immobilization, and physical therapy. Diagnostic procedures such as X-rays, and visits solely for observation or counseling, are not medical treatment by themselves.
Examples of Recordable and Non-Recordable Cases
These hypothetical scenarios show how the criteria apply:
- Recordable: a warehouse worker cuts a hand on a box cutter and receives four stitches. Sutures are medical treatment.
- Not recordable: the same cut is cleaned and covered with a butterfly bandage. That is first aid.
- Recordable: a technician strains a back lifting a motor, and the doctor restricts lifting to 10 pounds for two weeks, preventing routine job functions. That is restricted work.
- Recordable: a worker falls and an X-ray shows a cracked wrist bone, even if only a removable non-rigid wrap is used. A fractured or cracked bone is a significant diagnosed injury.
- Not recordable: an employee is sent for an X-ray after a minor bump, the result is normal and no treatment beyond ice is given.
Recordable Injury vs. Related Terms
Recordable vs. Reportable
Recording means entering a case on your OSHA 300 Log. Reporting means notifying OSHA directly. Under 1904.39, employers must report a work-related fatality within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours. Every reportable case is also recordable, but most recordable cases do not need to be reported to OSHA individually.
Recordable vs. Lost Time Injury
A lost time injury is a subset of recordable cases that involves days away from work. A case with only medical treatment or restricted duty is recordable but is not a lost time case.
Recording Requirements and Deadlines
- Who must record: employers with more than 10 employees at any time during the previous calendar year, unless their establishment is in a partially exempt low-hazard industry (1904.1 and 1904.2). OSHA can still require any employer to report severe injuries.
- Timing: record each case within seven calendar days of receiving information that a recordable case occurred (1904.29).
- Forms: the OSHA 300 Log, the 301 Incident Report (or equivalent) and the annual 300A Summary.
- Posting: post the certified 300A Summary from February 1 to April 30 each year.
- Retention: keep records for five years following the end of the calendar year they cover (1904.33).
- Electronic submission: as explained on OSHA's recordkeeping page, certain establishments must submit injury and illness data electronically each year by March 2.
When counting days away or restricted days, count calendar days, not including the day of injury, and you may cap the total at 180 days.
How to Calculate the Recordable Incident Rate
Recordable cases feed the total recordable incident rate (TRIR), which normalizes cases per 100 full-time workers:
TRIR = (Number of recordable cases × 200,000) ÷ Total hours worked
The 200,000 figure represents 100 employees working 40 hours a week for 50 weeks. In a hypothetical example, a facility with 6 recordable cases and 480,000 hours worked in a year would have a TRIR of (6 × 200,000) ÷ 480,000 = 2.5.
How to Determine Recordability Step by Step
- Confirm an injury or illness occurred. Symptoms alone, such as soreness reported without a diagnosis or treatment, may not yet meet the threshold.
- Decide work-relatedness. Apply the presumption in 1904.5 and check the listed exceptions, such as voluntary participation in a wellness program or eating food for personal consumption.
- Check whether it is a new case. A recurrence of a previously recorded injury may not be new unless the employee had recovered completely.
- Apply the general recording criteria. Look for any of the six outcomes, plus the specific criteria in 1904.8 through 1904.11.
- Record within seven days. Enter the case on the 300 Log and complete the 301 form.
- Update as the case develops. Add days away or restrictions, and reclassify the case if it becomes more serious.
Common Recordkeeping Mistakes
- Treating prescriptions as first aid: a prescription written for a work injury makes the case recordable, even if the employee does not fill it.
- Missing restricted work: failing to record cases where a doctor limits routine job functions.
- Waiting for workers' compensation decisions: OSHA recordability is independent of whether a claim is accepted.
- Not recording contract or temporary workers you supervise day to day: these cases belong on your log.
- Discouraging reporting: employers must have a reasonable reporting procedure and may not retaliate against employees who report injuries (1904.35).
How SMS360 Helps
SMS360's Incident Management module gives teams a consistent way to report injuries from the field, record case details and track whether each case is recordable. Follow-up information such as days away or restrictions can be added as a case develops, and records are kept for reporting and audits. Dashboards help safety managers review recordable cases and trends across sites.
Frequently Asked Questions
What makes an injury OSHA recordable?
An injury or illness is OSHA recordable if it is work-related, is a new case and results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury or illness diagnosed by a physician or licensed health care professional. These criteria are set out in 29 CFR 1904.7.
Is a doctor visit an OSHA recordable injury?
Not by itself. A visit to a physician solely for observation, counseling or diagnostic tests such as X-rays is not medical treatment. The case becomes recordable if the provider gives treatment beyond first aid, prescribes medication, restricts work or diagnoses a significant condition such as a fracture.
Are prescription medications recordable?
Yes. A prescription medication, or a nonprescription medication recommended by a physician or licensed health care professional at prescription strength, is medical treatment under OSHA rules. The case is recordable even if the employee chooses not to fill the prescription, because recordability is based on the recommendation.
How long do I have to record an injury on the OSHA 300 Log?
You must enter each recordable injury or illness on the OSHA 300 Log and the 301 Incident Report within seven calendar days of receiving information that a recordable case occurred. Records must then be kept for five years following the end of the calendar year they cover, and updated during that period.
