Is This Injury OSHA Recordable? The Decision Tree Every Safety Manager Needs

"Do I need to put this on the log?" It is the most common question in workplace safety recordkeeping, and getting it wrong in either direction has real consequences. Over-recording inflates your TRIR and DART rates, which can cost you contract bids, raise your insurance premiums, and put you on OSHA's radar for programmed inspections. Under-recording is worse — it is a citable violation that OSHA treats as a serious compliance failure, and it can lead to penalties of up to $16,550 per case you failed to record.

The good news is that OSHA has a clear, logical framework for making the call. It is a decision tree defined in 29 CFR 1904.4 through 1904.7, and every case follows the same path. The bad news is that most employers run only part of it — they jump straight to "did they go to the doctor?" and skip the two questions that come first. That shortcut is the source of most recordkeeping citations, because it produces wrong answers in both directions.

This guide walks the whole tree, in order, with the worked determinations and edge cases that decide real cases.

The Decision Tree: Four Questions, Asked in Order

For a case to be recordable, it must pass all four of these tests. The order matters — a "no" at any step ends the analysis, and running them out of sequence is how employers talk themselves into the wrong answer.

• Step 1: Did an injury or illness occur? An injury or illness is any abnormal condition or disorder — a cut, fracture, sprain, skin disease, respiratory condition, or subjective symptoms like persistent pain. No injury or illness, nothing to record.
• Step 2: Is it work-related? OSHA applies a geographic presumption: if it occurred in the work environment, it is presumed work-related unless one of nine specific exceptions applies.
• Step 3: Is it a new case? A recurrence of a previously recorded case is not recorded again. A genuinely new case is.
• Step 4: Does it meet a general recording criterion? Work-related new cases go on the log only if they trigger at least one of six specific outcomes.

If the answer at any step is no, the case is not recordable. If all four are yes, it goes on the log within seven calendar days. Our free recordability checker walks this same tree question by question.

Step 1: Did an Injury or Illness Actually Occur?

This step is usually straightforward. A broken bone, a burn, a diagnosed case of contact dermatitis — these are clearly injuries or illnesses. The cases that create confusion are exposures without symptoms.

If an employee is splashed with a chemical but shows no signs of irritation, illness, or abnormal condition, no injury or illness has occurred and there is nothing to record. The exposure alone is not the case; the abnormal condition is.

Two wrinkles are worth internalizing, because they pull in opposite directions.

Preventive treatment can create a recordable case even without symptoms. If the employer provides medical treatment as a precaution — a course of antibiotics after a needlestick, for example — the case may become recordable because of the treatment provided, not because of the exposure. The treatment is the trigger.

But "we gave them oxygen as a precaution" is not the same analysis. Administering oxygen is medical treatment for Part 1904 purposes, not first aid. If a symptomatic employee is given oxygen for a work-related condition, the case is recordable regardless of why the oxygen was given — protocol, local ordinance, or a responder's judgment. If the employee shows no signs or symptoms at all, the case is not recordable — but the reason is that no injury or illness occurred and step 1 fails, not that oxygen counts as first aid. That distinction sounds academic until an employee with a headache and nausea after a fume release is given oxygen and sent home, and the case is quietly left off the log.

Step 2: Is It Work-Related?

This is where most recordability disputes happen. OSHA defines the work environment broadly under 1904.5: it includes the establishment and any other location where employees are present as a condition of their employment. Your parking lot, a client's job site, a hotel during a business trip, and a company vehicle are all part of the work environment. Injuries in each of those settings start out presumed work-related.

The Geographic Presumption

Under 29 CFR 1904.5(a), if the injury or illness occurred in the work environment, it is presumed work-related unless it falls under one of the specific exceptions. You do not need to prove that work caused it. The burden runs the other way: if you believe a case is not work-related, it is on you to show that an exception applies.

This is the single most misunderstood rule in Part 1904. "We don't know what caused it" is not a basis for leaving a case off the log — an unexplained injury that happened at work is recordable.

The Nine Exceptions to Work-Relatedness

Section 1904.5(b)(2) lists nine situations where an injury or illness that occurs in the work environment is nonetheless not work-related:

• The injury or illness occurs at work but results solely from a non-work-related event or exposure that occurs outside the work environment. Example: an employee has an asthma attack at work triggered by a personal allergy unrelated to any workplace exposure.
• The condition involves signs or symptoms that surface at work but result solely from a non-work-related event or exposure. Example: an employee develops a rash at work, but it is diagnosed as a reaction to a new laundry detergent used at home.
• The injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical examination, flu shot, or exercise class. Note the word voluntary — a required physical is a different matter.
• The injury or illness is solely the result of an employee eating, drinking, or preparing food or drink for personal consumption. Example: an employee burns their hand microwaving personal food in the break room. But if the microwave malfunctions due to faulty workplace wiring, the case is work-related — the workplace contributed.
• The injury or illness is solely the result of an employee doing personal tasks at the establishment outside of their assigned working hours.
• The injury or illness is solely the result of personal grooming, self-medication for a non-work-related condition, or is intentionally self-inflicted.
• The injury or illness is caused by a motor vehicle accident that occurs on a company parking lot or company access road while the employee is commuting to or from work. The commuting qualifier does real work here: the same crash in the same lot during the workday, on a work errand, is recordable.
• The illness is the common cold or flu. This exception does not extend to contagious diseases like tuberculosis, brucellosis, hepatitis A, or plague, which are work-related if the employee is infected at work. COVID-19 technically sits outside this exception too, but since March 31, 2026 OSHA has an enforcement policy treating COVID-19 like the cold and flu — it will not cite employers for leaving COVID-19 cases off the log. That is enforcement discretion, not a rule change.
• The illness is a mental health condition that is not caused by a work-related event or exposure. Update (July 2026): the Fifth Circuit has vacated the federal mental-illness recording provision, 1904.5(b)(2)(ix), as exceeding OSHA's statutory authority — see the full analysis of mental health recordability and the Exxon Mobil decision for the current state of play, including why state-plan rules are unaffected for now.

Pre-Existing Conditions and Significant Aggravation

A work event or exposure that significantly aggravates a pre-existing condition makes the case work-related and recordable. "Significantly aggravated" means the work event caused the condition to become materially worse — requiring medical treatment where none was needed before, causing days away or restriction that would not otherwise have occurred, or producing a structural change such as a herniated disc in someone with a history of back problems.

Normal day-to-day fluctuation in a chronic condition is not significant aggravation. The test is whether work made it materially worse, not whether the employee felt it at work. This is a common enough determination that we cover it in depth in recording aggravation of a pre-existing condition.

Where the Employee Was Matters More Than You Think

Because the work environment extends past your four walls, several categories of case surprise employers:

• Travel and company vehicles. An employee on travel status is generally in the work environment for the whole trip, with carve-outs for genuine personal detours and for the "home away from home" a hotel becomes. The rules are specific enough to have their own guide: business travel and company-vehicle injuries.
• Telework. A home office is the work environment while the employee is performing work duties there — but the household itself is not. See is a work-from-home injury recordable.
• Supplied workers. Whether a temp or staffing-agency worker's case belongs on your log turns on day-to-day supervision, not payroll. That is a separate question from whether the case is recordable at all, and it is answered in who records a temp worker's injury.

Step 3: Is It a New Case?

This is the step most employers skip entirely, and it cuts both ways — it prevents double-recording a recurrence, and it forces recording of a genuine second case that felt like "the same old injury."

Under 29 CFR 1904.6(a), you must treat an injury or illness as a new case if either:

1. The employee has not previously experienced a recorded injury or illness of the same type that affects the same part of the body; or
2. The employee previously experienced a recorded injury or illness of the same type affecting the same part of the body, but had recovered completely — all signs and symptoms had disappeared — and an event or exposure in the work environment caused the signs or symptoms to reappear.

Both halves matter. "Same type, same body part" is the test for whether you are even looking at a potential continuation. Complete recovery is the test for whether a reappearance starts a new case.

If an employee's symptoms never fully resolved and they flare up again, that is a continuation of the existing case, not a new one. You do not create a second log entry; you update the original entry if the outcome changes — for example, if a case previously recorded as "other recordable" now involves days away.

Two Implementation Rules Worth Knowing

Chronic occupational illnesses are recorded once. Under 1904.6(b)(1), where signs or symptoms may recur without a new workplace exposure, the case is recorded only once. OSHA names occupational cancer, asbestosis, byssinosis, and silicosis. A silicosis case does not generate a fresh log entry each time the employee's symptoms worsen.

Chronic illnesses triggered by exposure are new cases each time. Under 1904.6(b)(2), where symptoms result from a workplace event or exposure — occupational asthma is OSHA's example — each incident is treated as a new case. The distinction is whether a workplace exposure caused this episode.

You may consult a physician, and if you do, you must follow the recommendation. Under 1904.6(b)(3), employers are not required to seek a medical opinion on whether a case is new. But if you do ask, you are bound by the answer. Where you receive conflicting recommendations, OSHA directs you to follow the most authoritative — best documented, best reasoned. You cannot shop for the opinion you prefer and discard the rest.

Step 4: Does It Meet a General Recording Criterion?

If a case is a work-related new injury or illness, you check it against the six general recording criteria in 29 CFR 1904.7. If any one is met, the case is recordable.

1. Death

Any work-related fatality is recordable. You must also report it to OSHA within eight hours — a separate duty on a separate clock. There is no time limit on when the death must occur relative to the injury: if an employee is injured at work and dies from that injury six months later, you record the death when it occurs and update the 300 Log entry.

2. Days Away from Work

If a physician or other licensed health care professional recommends days away from work, or the employee is unable to work due to the condition, the case is recordable — even if the employee ignores the recommendation and comes to work anyway. The recommendation itself triggers recordability. This is a frequent miss: the employee insists they are fine, works their shift, and the written "off work for three days" note never reaches the person keeping the log.

Day counting has its own rules — the count starts the day after the injury, runs in calendar days, and may be capped at 180. Under 1904.7(b)(3)(viii) you may cap the total at 180 calendar days and are not required to track beyond that, and the cap is the combined days-away-plus-restriction total. The mechanics are covered in counting days away and restricted days.

3. Restricted Work or Job Transfer

If an employee is kept from performing one or more routine functions of their job, or is transferred to a different job, the case is recordable. OSHA defines routine functions as "those work activities the employee regularly performs at least once per week."

That definition is narrower than most employers assume. Being unable to do something the employee does twice a year is not a restriction. Being unable to do something they do every Monday is.

Restriction that applies only on the day of the injury does not need to be recorded — it becomes recordable starting the day after.

4. Medical Treatment Beyond First Aid

This is the most common recording trigger and the one that causes the most confusion. OSHA maintains a finite, exhaustive list of 14 treatments that qualify as first aid, at 1904.7(b)(5)(ii). Anything not on that list is medical treatment, and the case is recordable.

Two properties of that list decide most arguments:

• It is closed. Prescription medication (even a single dose), sutures, staples, surgical glue, rigid splints, and physical therapy are all medical treatment because they are not on the list.
• Who provides the treatment does not matter. A treatment on the first-aid list stays first aid even when a physician administers it, and a treatment off the list is medical treatment even when a supervisor administers it. "They went to the ER" is not the test; what was done there is.

We cover the full list and the boundary cases in first aid vs. medical treatment — that guide is the place to resolve a specific treatment question.

5. Loss of Consciousness

Any work-related loss of consciousness is recordable, regardless of duration and regardless of whether any other criterion is met. An employee who faints for five seconds and immediately returns to work with no treatment has a recordable case. There is no de minimis exception.

6. Significant Diagnosed Injury or Illness

Certain conditions are recordable at the time of diagnosis by a physician or other licensed health care professional, even with no treatment, no days away, and no restriction. OSHA names four: cancer, chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum.

A fractured toe that requires no treatment and no time away from work is still recordable. So is a hairline crack found incidentally on an X-ray taken for another reason, if it is work-related.

Special Recording Rules Beyond the General Criteria

Four categories of case have their own recording rules that operate instead of — not in addition to — the general criteria. If you run one of these cases through the six criteria above, you will get the wrong answer.

• Needlestick and sharps injuries (29 CFR 1904.8). All work-related needlesticks and cuts from sharp objects contaminated with another person's blood or other potentially infectious material are recordable — regardless of treatment provided. An untreated contaminated needlestick is recordable; running it through "was there medical treatment?" produces a false negative.
• Hearing loss (29 CFR 1904.10). A recordable standard threshold shift is a change of 10 dB or more, averaged at 2000, 3000, and 4000 Hz in either ear, when the employee's total hearing level at those frequencies is 25 dB or more above audiometric zero. Age adjustment is permitted for the shift, not for the 25 dB check.
• Tuberculosis (29 CFR 1904.11). Recordable when an employee exposed to a known case of active TB in the work environment subsequently develops a positive TB skin test or is diagnosed with active TB.
• Medical removal (29 CFR 1904.9). If an employee is medically removed from their job under the requirements of an OSHA health standard — the lead or cadmium standards, for example — the case is recordable.

Heat illness, by contrast, has no special recording rule: heat cases run through the ordinary general criteria like any other condition, which is covered in logging heat cases under the 2026 Heat NEP.

The Clock, and Who Makes the Call

Recordability is not just a question of whether — it is a question of when.

You have seven calendar days from the moment you learn of a recordable case to enter it on the 300 Log (1904.29(b)(3)). The clock starts at employer awareness, not at the incident date. A case that happened three weeks ago but only reached you today starts its seven days today — and a case a supervisor knew about two weeks ago started its clock two weeks ago, whether or not the news travelled.

The determination is the employer's, not the physician's and not the insurance carrier's. A doctor tells you what treatment was provided and what work restrictions apply; you apply Part 1904 to those facts. A workers' compensation adjuster decides whether a claim is compensable under state law, which is a different question with a different standard — a denied comp claim can be a recordable case, and a paid comp claim can be non-recordable. That mismatch is common enough to have its own guide: workers' comp denied but OSHA recordable.

Write down the reasoning, not just the conclusion. The determination that protects you two years later is the one with a one-line rationale attached — "Not recordable: symptoms resolved with ice only, no restriction, 1904.7(b)(5)(ii)(B)." An inspector asking why a case is off the log is asking a question your memory cannot answer.

Putting It Into Practice: Worked Determinations

Each of these runs the full tree in order.

A slip with ice from the first aid kit. An employee slips on a wet floor, bruises a knee, applies ice, and returns to work with no restrictions. Step 1: yes, a bruise is an abnormal condition. Step 2: yes, in the work environment, no exception applies. Step 3: new case. Step 4: ice is on the first-aid list; no days away, no restriction, no loss of consciousness; a bruise is not one of the four significant diagnoses. Not recordable.

Gradual wrist pain diagnosed as carpal tunnel. Symptoms developed over several weeks; a doctor diagnoses carpal tunnel syndrome and prescribes a rigid wrist splint. Steps 1–3: yes — an abnormal condition, arising from work activities, not a continuation of anything previously recorded. Step 4: a rigid splint is medical treatment beyond first aid. Recordable. Note that the gradual onset does not matter; there is no requirement that a case arise from a single identifiable event.

A broken toe with no treatment. A coworker drops a tool on an employee's foot. The doctor says no treatment is needed — just a stiff-soled shoe. No days away, no restriction. Step 4: a fractured bone is a significant diagnosed injury under criterion 6. Recordable, on that criterion alone.

An epileptic seizure at work. An employee with documented epilepsy unrelated to work has a seizure and loses consciousness. Step 4 is plainly met — loss of consciousness. But the analysis never reaches step 4: Step 2 fails, because the condition resulted solely from a non-work-related medical condition and the work environment neither caused nor contributed. Not recordable. This is why order matters; starting at step 4 would have recorded it.

A back injury that "acted up again." An employee strained their back in March; the case was recorded with three days away. In August the pain returns after lifting a box. Step 3 decides it. If the employee's symptoms had fully resolved and the August lift brought them back, it is a new case with its own line. If the back never stopped bothering them, it is a continuation — update the March entry if the outcome has changed, and do not open a second one.

An unwitnessed injury with no known cause. An employee is found on the warehouse floor with a wrist fracture and does not remember what happened. There is no evidence of a personal medical event. Step 2: the geographic presumption applies and no exception has been shown, so it is work-related. Recordable. "We don't know what happened" is not an exception.

Frequently Asked Questions

Does an employee have to see a doctor for a case to be recordable? No. Loss of consciousness and the four significant diagnosed conditions are recordable without any treatment, and a physician's recommendation of days away is enough even if the employee never takes them. Conversely, seeing a doctor does not make a case recordable — what matters is whether the treatment provided falls off the 14-item first-aid list.

If the employee refuses treatment, is it still recordable? Yes, if a licensed health care professional recommended treatment that would have been medical treatment beyond first aid, or recommended days away or restriction. The recommendation triggers the criterion; the employee's compliance does not undo it.

Does the case go on the log if it happened in the parking lot? Usually yes — a company parking lot is part of the work environment. The narrow exception is a motor vehicle accident there while the employee is commuting to or from work. A slip on ice walking to the door is recordable if it meets a criterion.

What if the injury happened at another company's site? The work environment follows the employee. If your employee is injured at a client's facility while working, it is presumed work-related and goes on your log — subject to the supervision test if the worker is supplied by or to another employer.

We're a small employer — are we exempt? Possibly, but from recording, not from everything. Employers with 10 or fewer employees throughout the prior calendar year, and establishments in certain low-hazard industries, are partially exempt from routine 300 Log recordkeeping — but every covered employer must still report severe injuries under 1904.39, and a written BLS or OSHA survey request overrides the exemption. See do you need to keep an OSHA 300 Log.

How long do I have to make the determination? Seven calendar days from when you learn of the case, to enter it on the log. Where a determination is genuinely unresolved at day seven, record it and correct later if the facts change — the deadline is not tolled by uncertainty.

Does recording a case admit fault? No. OSHA states plainly that recording a case does not mean the employer or employee was at fault, that an OSHA rule was violated, or that the employee is eligible for workers' compensation. Recordability is a measurement standard, not a liability finding.

Where This Leaves You

Recordability is a determination you will make dozens of times a year, usually under time pressure and usually with incomplete facts. The employers who get it right are not the ones with the best memory for 1904.7 — they are the ones who run the same four questions in the same order every time and write down why.

LogStead runs that tree for you. The recordability wizard walks the 1904.5 work-relatedness test, the 1904.6 new-case question, and the general recording criteria in sequence for every case, and records the reasoning behind each call so the determination holds up long after the details are forgotten. Cases that clear the tree flow onto the right establishment's 300 Log with the seven-day clock tracked, day counts carried into your 300A totals and rates automatically, and privacy-concern cases flagged at entry so a name never lands on a Log copy it shouldn't. If you want to walk a single case through the same logic right now, the free recordability checker is open to anyone — no account needed.

This post is general compliance information, not legal advice. Verify current regulatory text against eCFR and your state plan's requirements — state-plan states such as California, Washington, and Oregon may impose additional or more stringent recording requirements.