A work-related case goes on the OSHA 300 Log when it results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness — or when a physician or other licensed health care professional diagnoses a significant injury or illness. That list, in 29 CFR 1904.7, is the whole test.
The six triggers
Two questions decide every case, in this order. Was it work-related? Then: did it produce one of these outcomes? Any single one is enough.
| Outcome | What it means in practice | 300A box |
|---|---|---|
| Death | A work-related fatality. Also reported to OSHA within 8 hours. | G |
| Days away from work | At least one calendar day away, counted from the day after the injury. | H |
| Restricted work or transfer | Kept from a routine job function, or from the full scheduled workday. | I |
| Medical treatment beyond first aid | Anything not on OSHA's closed first aid list — see below. | J |
| Loss of consciousness | Any duration, whatever the treatment. | J |
| Significant diagnosis | Cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum diagnosed by a physician or other licensed health care professional — recordable on the diagnosis alone. | J |
Work-relatedness comes first and is presumed: an injury or illness is work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing condition, unless one of the exceptions in 1904.5(b)(2) applies.
The first aid list is closed
This is the part that settles most arguments. OSHA does not ask you to judge whether a treatment was serious. It publishes a finite list of treatments that count as first aid, and states that anything not on the list is medical treatment. The list includes:
- Non-prescription medication at non-prescription strength
- Tetanus immunizations
- Cleaning, flushing or soaking wounds on the skin surface
- Bandages, gauze pads, butterfly bandages and Steri-Strips
- Hot or cold therapy
- Non-rigid means of support: elastic bandages, wraps, non-rigid back belts
- Temporary immobilization used only to transport an accident victim
- Drilling a fingernail or toenail, or draining a blister
- Eye patches, and removing a foreign body from the eye by irrigation or with a swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or simple means
- Finger guards, massages, and drinking fluids for relief of heat stress
Two things on the list are also not treatment at all: a visit to a doctor or other health care professional solely for observation or counseling, and diagnostic procedures — an X-ray, a blood test — including the prescription medication used only for diagnostic purposes.
The calls people get wrong
Recordable, even though it feels minor
- A prescription is written — whether or not it is ever filled (OSHA letter of interpretation, 10/29/2001)
- Stitches, staples, surgical glue or sutures on a cut
- A rigid splint or cast; rigid means of support of any kind
- Physical therapy or chiropractic treatment
- Any loss of consciousness, however brief
- A cracked bone found on an X-ray, with no treatment at all
Not recordable, even though it feels serious
- An ambulance ride and an emergency room visit that end in observation only
- A full set of X-rays and blood work that find nothing
- Ibuprofen at over-the-counter strength, however many doses
- A restriction imposed only for the day the injury happened
- An employee who works the full shift and every routine function, just more slowly
Restricted work has a precise definition worth learning: you are restricting work when you keep the employee from performing one or more routine functions of the job — activities performed at least once a week — or from working the full workday that would otherwise have been scheduled. A health care professional's recommendation to that effect counts even if you keep the employee on full duty.
Four cases with their own criteria
Some conditions are recordable on their own terms, whatever treatment followed. OSHA lists them in the overview it publishes with the forms, and they catch employers out precisely because the general test never fires.
| Condition | The test |
|---|---|
| Needlesticks and sharps injuries | Any needlestick or cut from a sharp object contaminated with another person's blood or other potentially infectious material. Treatment is irrelevant. |
| Medical removal | Any case requiring an employee to be medically removed under the requirements of an OSHA health standard — lead and cadmium are the usual ones. |
| Tuberculosis infection | A positive skin test or a diagnosis by a physician or other licensed health care professional after exposure to a known case of active tuberculosis. |
| Hearing loss | An audiogram showing a standard threshold shift in one or both ears — averaged at 2000, 3000 and 4000 Hz — and a total hearing level of 25 dB or more above audiometric zero in the same ear, averaged at the same frequencies. Both parts have to be true. |
The hearing loss criterion is the one most often applied wrongly, in both directions: a shift alone is not recordable if the total level is still under 25 dB, and a hearing level over 25 dB is not recordable without a shift. If your audiometric program flags a shift, work the two tests separately before anything reaches the log — the noise exposure calculator deals with the exposure side of the same program.
Recordable is not the same as compensable
Two different systems, two different tests, run by two different authorities. Recordability comes from 29 CFR Part 1904, a federal recordkeeping rule. Compensability comes from your state's workers' compensation law. They overlap, and they routinely disagree.
OSHA prints the point on the log instructions itself: cases listed on the Log are not necessarily eligible for workers' compensation or other insurance benefits
, and listing a case does not mean that the employer or worker was at fault or that an OSHA standard was violated
. Deciding recordability by asking whether the carrier accepted the claim is one of the most common ways a log goes wrong — in both directions.
Deadlines around a case
- 7 calendar days from receiving information about a case to decide whether it is recordable and get it onto the Log and the 301 (or an equivalent form).
- 8 hours to report a work-related fatality to OSHA — by phone, or through the online form.
- 24 hours to report a work-related in-patient hospitalization, amputation or loss of an eye. This applies to every employer, including those exempt from keeping the Log.
- 5 years to keep the Log, the annual summary and the 301 forms after the year they cover — updating stored Logs when a case is newly discovered or its classification changes.
One thing you cannot do
You cannot make a case disappear by making it awkward to report. 29 CFR 1904.35(b)(1)(i) requires a reasonable procedure for employees to report injuries and illnesses promptly and accurately, and states that a procedure is not reasonable if it would deter or discourage a reasonable employee from accurately reporting. Paragraph (b)(1)(iv) prohibits discharging or in any manner discriminating against an employee for reporting one, and (b)(1)(iii) requires you to tell every employee that they have the right to report and that retaliation is prohibited.
That is worth remembering whenever a bonus, a safety incentive or a subcontractor prequalification is tied to a rate. The lower number is easy to obtain and expensive to defend.
Bottom line
- Work-related, then one of six outcomes: death, days away, restricted work or transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis.
- The first aid list is closed. If a treatment is not on it, it is medical treatment — no judgment call required.
- Observation and diagnostic procedures are not treatment; a prescription is, filled or not.
- Never decide recordability from the workers' compensation outcome.
- Once the year's cases are counted, the 300A summary helper totals the boxes and cross-checks them before you post the summary.