The carrier denied the claim. Does the case still go on your OSHA 300 Log?
The comp decision doesn't answer that, in either direction. OSHA decides recordability with its own two questions: was the case work-related under 29 CFR 1904.5, and did it meet a recording criterion under 1904.7? Neither question asks what the carrier did. A denied claim can be recordable. A paid claim can stay off the log. And a case can be recordable even when the claim never paid a day of lost wages.
OSHA put the principle in writing in 1994: "Workers' compensation determinations do not impact the recordability of cases under OSHA recordkeeping requirements." This post skips the general explainer. It shows the specific places where the two systems split, walks three cases through to the log entry, and covers the timing problem that causes most of the errors.
The four splits
Most of the confusion comes from four combinations. Each one is a case where the comp answer and the OSHA answer point in different directions.
| Comp outcome | OSHA outcome | A typical case | Why OSHA decides differently |
|---|---|---|---|
| Denied | Recordable | A back strain treated with a prescription muscle relaxant, three days off work, claim denied after a positive post-incident drug screen | The reason for the denial is not one of the work-relatedness exceptions in 1904.5(b)(2). The case met two recording criteria: medical treatment beyond first aid, and days away |
| Paid (medical only) | Not recordable | A cut closed with a butterfly bandage at urgent care, and the carrier paid the visit | Butterfly bandages are on OSHA's first-aid list, 1904.7(b)(5)(ii)(D), and first aid doesn't depend on who provides it, 1904.7(b)(5)(iv) |
| Paid | Not recordable | An employee rear-ended in the company parking lot while driving home | 1904.5(b)(2)(vii) excludes motor vehicle accidents on a company lot or access road while commuting, whatever comp does with the claim |
| Paid, no lost wages | Recordable | A cut closed with sutures, and the employee back on the job the same shift | Sutures are medical treatment, not first aid (1904.7(b)(5)(ii)(D)), so the case is recordable even though nobody missed a day |
Two more splits show up often enough to name. The first is cumulative trauma such as carpal tunnel syndrome, where a claim may be denied but the case still goes on the log. OSHA's 1994 letter covered it directly; see below. The second is a pre-existing condition that a work event significantly aggravated. The carrier may deny on "pre-existing" grounds, but 1904.5(a) treats significant aggravation as work-related.
What OSHA tests, and what it ignores
OSHA's first question is work-relatedness. 29 CFR 1904.5(a) reads:
You must consider an injury or illness to be work-related if an event or exposure in the work environment either caused or contributed to the resulting condition or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for injuries and illnesses resulting from events or exposures occurring in the work environment, unless an exception in §1904.5(b)(2) specifically applies.
The exceptions in 1904.5(b)(2) are a closed list. Among them: members of the public, voluntary wellness or recreational activity, eating and drinking for personal consumption, personal tasks outside working hours, commuting car accidents in the company lot, and the common cold or flu. "The carrier denied the claim" isn't on it. Neither are the reasons carriers commonly give: a failed drug screen, late notice, a missed medical exam, or a state statutory defense. Comp systems decide compensability under each state's own law, which asks a different question for a different purpose.
The second question is the recording criteria. 1904.7(a) makes a work-related case recordable if it results in "death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness", or involves a significant injury or illness diagnosed by a physician or other licensed health care professional. The first-aid list in 1904.7(b)(5)(ii) is also closed: 1904.7(b)(5)(iii) says "this is a complete list of all treatments considered first aid for part 1904 purposes." The first aid vs. medical treatment guide walks through all fourteen items.
Then the clock. Under 1904.29(b)(3), you must enter each recordable case "within seven (7) calendar days of receiving information that a recordable injury or illness has occurred." The seven days start when you learn of the case. A comp decision usually comes later, so it can't be what you wait for.
Two questions, no third
Work-related under 1904.5? Meets a recording criterion under 1904.7? If both are yes, the case goes on the log within seven calendar days. Neither question asks about the comp claim, and neither does the log.
Three worked determinations
Each walk-through uses the same three steps: work-relatedness, recording criteria, then the log entry. The column letters are those on OSHA Form 300.
1. The denied back strain
Facts. A warehouse associate strains his lower back lifting a pallet on a Tuesday. Urgent care prescribes a muscle relaxant and writes him off work for the rest of the week, so he misses Wednesday, Thursday and Friday. The post-incident drug screen comes back positive, and under its state's law the carrier denies the claim.
Step 1: work-related? The lift happened at work, in the course of his job, so 1904.5(a) presumes work-relatedness. None of the 1904.5(b)(2) exceptions covers a positive drug screen. Yes.
Step 2: a recording criterion? Two of them. A prescription medication isn't on the first-aid list, which covers only a non-prescription medication at non-prescription strength (1904.7(b)(5)(ii)(A)). And he has days away from work. Yes, recordable.
Step 3: the entry. Days away is the more serious outcome, so check column H. Under 1904.7(b)(3)(i) you begin counting "on the day after the injury occurred", which makes column K 3. The entry is due within seven calendar days of when you learned of the injury, whatever the carrier is still deciding.
2. The paid butterfly bandage
Facts. A maintenance tech catches a forearm on a sheet-metal edge. At urgent care, a physician cleans the cut and closes it with butterfly bandages, and the tech goes back to work. The carrier pays the visit as a medical-only claim.
Step 1: work-related? Yes. It's an equipment injury during assigned work.
Step 2: a recording criterion? No. Butterfly bandages and Steri-Strips are on the first-aid list at 1904.7(b)(5)(ii)(D). That a physician applied them changes nothing: under 1904.7(b)(5)(iv), the listed treatments are first aid "regardless of the professional status of the person providing the treatment." No days away, no restriction, no loss of consciousness. Not recordable.
Step 3: the entry. Nothing goes on the 300 Log. The comp claim file exists, and it stays in the comp file. Keep a short written note of why the case wasn't recordable, so that next year nobody adds it because "comp paid on it."
3. Sutures, back the same shift
Facts. A line worker's hand is cut on a guard edge. The clinic closes it with four sutures, and she's back on the line before the end of her shift. There are no lost wages, so the carrier pays it as medical-only.
Step 1: work-related? Yes.
Step 2: a recording criterion? Yes. The same paragraph that lists butterfly bandages as first aid says "other wound closing devices such as sutures, staples, etc., are considered medical treatment" (1904.7(b)(5)(ii)(D)). Medical treatment beyond first aid makes the case recordable. Recordable.
Step 3: the entry. No days away and no restriction, so check column J (other recordable cases). Columns K and L stay at zero. This is the case loss runs most often miss. A medical-only claim with no indemnity reads as minor, but the log doesn't track lost wages.
The fourth split, the parking-lot rear-end, takes one line. Work-relatedness fails at step 1 under 1904.5(b)(2)(vii), so nothing goes on the log, whatever comp does with the claim.
When the comp decision comes after you've recorded
Here the two timelines collide. You recorded the back strain on day five. On day forty the carrier denies. Should the case come off the log?
No, not because of the denial. A later comp decision isn't new information about work-relatedness or the recording criteria. It's an answer to a different question. A case comes off the log when the facts show it never met OSHA's test: for example, it turns out the injury didn't happen at work.
The reverse holds too. If a case is genuinely uncertain on OSHA's own criteria when the seven days run out, OSHA's advice in a 1993 letter was to record it and correct it later: "Questionable cases should be recorded on the Log and lined out at a later date if they are found not to be recordable." Waiting on the carrier inverts that advice.
What OSHA has said in writing
OSHA has addressed the comp question in several letters of interpretation. They interpret the recordkeeping guidelines that came before today's Part 1904, and osha.gov marks each one as an "OSHA Archive Document" that "may no longer represent OSHA Policy." Today's rule doesn't depend on them, because it doesn't mention comp at all. They're still the clearest statement of why the two systems are separate.
- May 25, 1994, to Kemper Risk Management Services: "Workers' compensation determinations do not impact the recordability of cases under OSHA recordkeeping requirements." And: "Some cases may be covered by workers' compensation but are not recordable; other cases may be OSHA recordable but are not covered by workers' compensation." On carpal tunnel: "a positive diagnosis of carpal tunnel syndrome which meets the work related criteria as outlined above must be recorded on the OSHA Log, whether it is determined to be compensable under the Workers' Compensation system or not."
- April 24, 1992, to Brown & Root: "Injuries and illnesses that are OSHA recordable may also be covered by either workers' compensation or private insurance." The letter goes on: the recording "must be determined solely on the basis of the OSHA criteria."
- June 21, 1993, to Jerry A. Carter (disputed cases): the record-it-then-line-it-out advice quoted above.
Keeping the two files apart
The fix is procedural, not legal. Most of the errors come from letting one file drive the other.
- Make the recordability call yourself, in writing, within seven days. Use the two OSHA questions, and write down "not recordable" decisions as well as recordable ones. The adjuster's decision is a claim decision.
- Don't build the 300 Log from the loss run. A loss run includes paid first-aid claims that don't belong on the log. It leaves out denied claims that do, and medical-only claims look too small to matter.
- Reconcile once a year, before you certify the 300A. Compare the log to the claims list and look for the four splits above. Every difference should have a reason you can state in one sentence.
The difference reaches your rates too. TRIR and DART are built from the 300 Log, so a denied-but-recordable case counts. The TRIR and DART explainer covers the math, and the free rate calculator shows what one case does to each rate. For the full recordability walk-through, see is this injury OSHA recordable?. The 300 Log guide covers each column, and the common recordkeeping mistakes post shows how these errors turn into citations.
LogStead's recordability wizard asks OSHA's questions in order: work-related, death, new case, days away, restriction, medical treatment, loss of consciousness, and significant diagnosis. Each answer cites the 1904 section it applied. None of its questions asks about the comp claim, because the regulation doesn't either. Run a case through the free recordability checker, or keep the log, the 300A and the year-end reconciliation in one place with a 14-day trial.