Free OSHA Compliance Tool

Is This Injury OSHA Recordable?

Walk through the official decision tree from 29 CFR 1904 and get a clear answer in under 60 seconds — no account required.

Recordability Decision Tree

1Question 1 of up to 8

Did the injury or illness result from an event or exposure in the work environment?

This tool gives general information based on OSHA’s recordkeeping rules (29 CFR Part 1904) to help you understand your obligations. It is not legal advice and does not replace the current regulation or the judgment of a qualified safety professional. Rules can change and edge cases exist — verify results against the current text at osha.gov/recordkeeping and consult a professional before making a compliance decision.

How the OSHA Recordability Test Works

Under OSHA’s recordkeeping standard (29 CFR Part 1904), most employers with more than ten employees must maintain a log of work-related injuries and illnesses. But not every workplace incident qualifies — OSHA uses a specific decision tree to determine if a case is “recordable,” and the steps run in order. A case only reaches the next question if it passed the one before it.

  1. Did an injury or illness occur? A scratch that needs nothing, or a report with no diagnosed condition behind it, never enters the analysis.
  2. Is it work-related? Events or exposures in the work environment presumptively count (1904.5), subject to nine narrow exceptions listed below.
  3. Is it a new case? A recurrence of a case you already logged is not a second case (1904.6).
  4. Does it meet a general recording criterion? Death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a licensed health care professional (1904.7).
  5. Does a special rule apply? Needlesticks, hearing loss, tuberculosis, and medical removal have their own criteria (1904.8–1904.11).

If a case clears the tree, it goes on your OSHA 300 log within seven calendar days of learning it occurred (1904.29(b)(3)). The seven days runs from when you learned about the case, not from the date of the incident — a distinction that matters when an employee reports an injury weeks later.

When Is an Injury “Work-Related”?

OSHA starts from a presumption: if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing condition, the case is work-related. Section 1904.5(b)(2) then lists nine situations that are not work-related, even though they happen at work:

  • The case results solely from a non-work event or exposure that happened outside the work environment.
  • Signs or symptoms merely surface at work but result solely from a non-work event or exposure.
  • It results solely from voluntary participation in a wellness program, or a medical, fitness, or recreational activity — blood donation, a physical, a flu shot, an exercise class.
  • It results solely from eating, drinking, or preparing food or drink for personal consumption.
  • It results solely from personal tasks at the establishment outside assigned working hours.
  • It results solely from personal grooming, self-medication for a non-work condition, or is intentionally self-inflicted.
  • It is caused by a motor vehicle accident on a company parking lot or access road while the employee is commuting to or from work.
  • It is the common cold or flu. (Contagious diseases such as tuberculosis are not covered by this exception.)
  • It is a mental health condition not caused by a work-related event or exposure. (Update, July 2026: the Fifth Circuit vacated the federal mental-illness recording provision, 1904.5(b)(2)(ix) — see the current state of play; state-plan rules are unaffected for now.)

The word solely is doing the work in most of these. OSHA’s standard is contribution, not sole causation — if the work environment contributed at all, the exception does not apply, even when personal factors also played a role. That is also why significant aggravation of a pre-existing condition is recordable: the employee’s history does not undo the workplace’s contribution.

First Aid vs. Medical Treatment: OSHA’s Complete List

This is the single most common point of confusion, and the rule is more mechanical than most people expect. OSHA publishes a finite, exhaustive list of first-aid treatments in 29 CFR 1904.7(b)(5)(ii). If a treatment is on the list, it is first aid. If it is not on the list, it is medical treatment and the case is recordable. There is no gray area in the rule itself — only in how people apply it.

  • Non-prescription medication at non-prescription strength
  • Tetanus immunizations (but not other immunizations, such as hepatitis B or rabies)
  • Cleaning, flushing, or soaking wounds on the skin surface
  • Wound coverings — bandages, Band-Aids, gauze pads
  • Butterfly bandages or Steri-Strips (but not sutures, staples, or other wound-closing devices)
  • Hot or cold therapy
  • Non-rigid support — elastic bandages, wraps, non-rigid back belts
  • Temporary immobilization devices used while transporting an accident victim
  • Drilling a fingernail or toenail to relieve pressure, or draining a blister
  • 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
  • Finger guards
  • Massages (but not physical therapy or chiropractic treatment)
  • Drinking fluids for relief of heat stress

Oxygen is not on that list. OSHA decided in the 2001 recordkeeping rulemaking that administering oxygen is medical treatment, and its interpretation letters say so directly: “The administration of oxygen is considered medical treatment for OSHA injury and illness recordkeeping purposes.” So a worker who is symptomatic of a work-related injury or illness — respiratory distress after smoke inhalation, or a heat case — and is given oxygen has a recordable case. The often-quoted exception is narrower than it sounds: oxygen given to a worker showing no symptoms at all, purely as a precaution, is not recordable because no injury or illness occurred in the first place — not because the oxygen counted as first aid.

Two consequences catch people out. First, who provides the treatment is irrelevant — a physician applying a butterfly bandage is still providing first aid, and an on-site responder doing something off the list is still providing medical treatment. Second, identical injuries can land differently: the same cut is non-recordable with a Steri-Strip and recordable with three sutures. Our full guide to the first aid line works through the gray areas in detail.

The Cases That Cause the Most Arguments

Most recordability disputes are not about the decision tree — they are about a handful of recurring fact patterns where reasonable people read the same rule differently. Each of these has its own analysis:

  • Injuries at home — recordable only when the injury occurs while performing work for pay and is directly related to that work, not to the home environment.
  • Business travel and company vehicles — travel status keeps an employee in the work environment, but personal detours and the ordinary commute break the chain.
  • Heat illness — drinking fluids for heat stress is first aid; IV fluids or an ER evaluation are not.
  • Hearing loss — a special rule under 1904.10, not the general criteria: a standard threshold shift plus a total 25 dB level.
  • COVID-19 — sits outside the cold-and-flu exception as written, but since March 31, 2026 OSHA has exercised enforcement discretion not to cite for it under Part 1904.
  • Workers’ comp denials — a denied claim says nothing about recordability. They are two independent systems with different tests.

When you genuinely cannot tell, record the case. Reclassifying later is straightforward; a missing entry found during an inspection is not.

What Happens After You Decide It’s Recordable

A recordable case creates three obligations, not one. It goes on the OSHA 300 log within seven calendar days; it needs a corresponding Form 301 incident report (or an equivalent) within the same window; and at year end it rolls into the Form 300A annual summary, which must be certified by a company executive and posted from February 1 through April 30.

Separately, the most severe outcomes carry a reporting clock that runs in hours, not days — 8 hours for a work-related fatality, 24 hours for an in-patient hospitalization, amputation, or loss of an eye (1904.39). That obligation is independent of the log: you report those to OSHA directly, and you still record them.

Why Accurate Recordkeeping Matters

OSHA can issue citations up to $16,550 per violation for recordkeeping failures — and willful or repeated violations can reach $165,514. Beyond fines, your OSHA 300 log feeds directly into your DART and TRIR rates, which affect your Experience Modification Rate (EMR) for workers’ compensation insurance and are routinely requested during contractor pre-qualification.

Those same rates feed OSHA’s own targeting: establishments whose rates run well above their industry average are more likely to be selected for a programmed inspection. Accurate records protect you financially while helping you spot hazards before they become patterns — and the mistakes that draw citations are usually process failures, not judgment calls.

Common Questions

Does an employee visiting a doctor make the case recordable?
No. Recordability turns on the treatment provided, not on who provided it or where. A doctor’s visit that produces only observation, an examination, diagnostic tests, or a first-aid treatment from the 1904.7(b)(5)(ii) list does not make the case recordable.
Is a case recordable if the employee misses no work?
Yes, if it meets any other criterion. Medical treatment beyond first aid, loss of consciousness, or a significant diagnosis all make a case recordable with zero days away. Days away affects the classification and your DART rate, not whether the case is logged at all.
Do I have to keep a 300 log at all?
Not necessarily. Employers with ten or fewer employees company-wide throughout the prior calendar year, and establishments in partially exempt low-hazard industries (Appendix A to Subpart B), are excused from routine recordkeeping — though both must still report severe injuries under 1904.39. See the exemption rules in full.
If a case is recordable, do I also have to submit it to OSHA?
Only if the establishment is covered by the electronic submission rule (1904.41), which depends on peak headcount and industry — not on whether you had any recordable cases. Check with the ITA submission checker.
Can I remove a case from the log later?
You can and should correct the log when the facts change — 1904.33(b)(1) requires you to keep the stored log updated with newly discovered cases and changes to classification, description, or outcome, for five years following the year it covers. Correcting a good-faith entry is normal; deleting a case to improve a rate is not.

More guides on recordkeeping practice are on the LogStead blog.