A work-related concussion is commonly OSHA recordable, but do not make the call from the word “head bump” alone. The key facts are whether work caused or contributed to the condition, whether it is a new case and whether a physician or other licensed health-care professional diagnosed a significant injury or illness—or another recording criterion occurred. A diagnosed concussion is specifically the sort of fact that deserves a careful, documented answer.
Why a concussion can meet the recording test
29 CFR 1904.7 says a work-related new case is recordable when it involves a significant injury or illness diagnosed by a physician or other licensed health-care professional, even without days away, restriction, medical treatment beyond first aid or loss of consciousness. OSHA lists a diagnosed concussion among examples of significant diagnosed injuries in its recordkeeping guidance.
| Fact pattern | Recordkeeping direction | What still needs checking |
|---|---|---|
| Worker strikes head on shelving; clinician diagnoses concussion | Usually recordable | Work-relatedness and new-case facts |
| Worker feels dizzy at work; no diagnosis and symptoms tied to non-work illness | Not automatically recordable | Cause, treatment and diagnosis |
| Concussion after a work vehicle collision | Often recordable; may have reporting implications | Event facts and severe-event outcomes |
| Headache after a personal recreational activity at work | May fall within an exception | Exact activity and exposure |
A diagnosis does not remove the need to establish that the case is work-related.
The first few hours: care before classification
Treat suspected concussion as a health and safety issue first. Follow emergency procedures, seek appropriate medical evaluation and do not pressure the worker to “sleep it off” or return to hazardous work. This article is about recordkeeping, not clinical advice. Once the worker is safe, preserve the facts: the task, location, contact or exposure, witnesses, clinician diagnosis and any work-status instruction.
Those details matter because a worker may have symptoms from a non-work condition that simply become noticeable during a shift. The work-relatedness rule presumes cases arising from workplace events or exposures are work-related unless a specified exception applies. Read the exceptions carefully; they are narrower than ordinary intuition.
A worked scenario
Priya is checking inventory from a step platform. She stands up into a low steel beam, sits down immediately and later reports nausea. A clinician diagnoses a concussion and says she cannot drive forklifts or work at height for five days. The event occurred while Priya was doing assigned work; assuming there is no contrary causal fact, work-relatedness is clear. The diagnosed concussion can meet the significant-injury criterion. The driving and height limits may separately create restricted-work days. Record the case and keep the specific work-status dates.
Now change the facts: Priya reports a headache after arriving at work but says she fell at home the previous night. No workplace event or exposure contributed, and the clinician confirms the home cause. A diagnosis alone does not make this an OSHA case. The diagnosis has importance, but the causal gate comes first.
Do not rely on loss of consciousness alone
Loss of consciousness is one general recording criterion, but it is not a prerequisite for a recordable concussion. Equally, a worker who blacked out at work may have a recordable case for that outcome even before a concussion diagnosis is made. Capture what actually happened rather than creating a rule of thumb around whether somebody “was knocked out”.
Treatment can also independently matter. Prescription medication, sutures for an associated wound, restrictions or days away can support recordability. The medical-treatment guide and restricted-work guide help with those branches.
Log it cleanly and protect privacy
If the case is recordable, enter it on the 300 Log and prepare Form 301 or an equivalent within seven calendar days of learning it is recordable. Record the diagnosis and event accurately without publishing unnecessary clinical detail. A concussion is not automatically one of OSHA’s privacy-case categories, so do not redact it by reflex; apply the exact privacy rule and company privacy controls.
If facts remain unclear—perhaps the worker had a prior concussion or competing explanation—record the open question and obtain the clinician’s documented view. Job13’s free check can organise the Part 1904 analysis, but medical assessment and genuine causation uncertainty need human evidence.
Follow the work-status instruction through
Concussion restrictions are often task-specific: no driving, no work at height, limited screen exposure, quiet work only or no overtime. Translate each instruction into the employee’s routine job functions rather than writing “light duty” and moving on. Note the date of each change and whether a normal task resumed. That creates the factual basis for any restricted-work day count and reduces the risk that a worker returns to a safety-sensitive task before a qualified clinician has released them.
If the worker is a contractor or temporary worker, confirm which employer is responsible for the Part 1904 entry before the details drift between companies. Preserve the host-site event facts and communicate the work status securely. The need for a correct record never overrides a worker’s need for confidential medical care.
At closure, confirm the final diagnosis and return-to-normal-duty date with the designated recordkeeper.
Frequently asked questions
Is a diagnosed concussion OSHA recordable without missed work?
It can be. A work-related new case involving a significant injury or illness diagnosed by a licensed health-care professional is recordable even when there are no days away or work restrictions. Confirm work-relatedness and new-case status.
Does a worker need to lose consciousness for a concussion to be recordable?
No. Loss of consciousness is one independent criterion, but a diagnosed work-related concussion can meet the significant-diagnosis criterion without it.
What should be documented after a possible workplace concussion?
Record the work activity, event or exposure, timing, witness facts, clinician diagnosis, treatment, work-status restrictions and return date. Keep the account factual; do not ask a supervisor to make a medical diagnosis.
Is a concussion from a commute OSHA recordable?
Usually not simply because it is reported at work. Work-relatedness depends on the circumstances, and commuting is treated differently from work travel. Review the exact Part 1904 work-relatedness rule for the location and activity.
