"OSHA 1904" is shorthand for Part 1904 of Title 29 of the Code of Federal Regulations: the rule that tells US employers which workplace injuries and illnesses to record, which forms to keep, and what to report to the government. It is short enough to read in an afternoon and dense enough that most people never do. This guide walks through how Part 1904 is organised, which sections do the real work, and where employers most often go wrong, so you can find the right section fast instead of searching for it mid-incident.
What is OSHA 1904?
The formal title is "Recording and Reporting Occupational Injuries and Illnesses". Its purpose is to require employers to record and report work-related fatalities, injuries and illnesses. The text is published at 29 CFR Part 1904, and OSHA hosts its own copy and guidance at osha.gov/recordkeeping.
Two ideas are worth separating from the start, because the rule treats them as different duties:
- Recording means writing a case on your internal paperwork: the OSHA 300 Log, the 301 incident report and the 300A annual summary.
- Reporting means telling OSHA directly, for example within 8 hours of a work-related death or 24 hours of an in-patient hospitalisation, amputation or loss of an eye. Our post on recordable versus reportable covers that split.
Most "OSHA 1904" searches are really about one of those two questions: does this case go on my log, or do I have to call OSHA?
How is Part 1904 organised?
Part 1904 has seven subparts. Per the published table of contents, they run as follows:
| Subpart | Title | What it does for you |
|---|---|---|
| A | Purpose | States the aim of the rule |
| B | Scope | Decides who is partially exempt (small employers and listed industries) |
| C | Recordkeeping Forms and Recording Criteria | The core: what counts as recordable and how to fill in the forms |
| D | Other OSHA Injury and Illness Recordkeeping Requirements | Multiple establishments, annual summary, retention, employee involvement |
| E | Reporting Fatality, Injury and Illness Information to the Government | Fatality and hospitalisation reporting, data requests, electronic submission |
| F | Transition From the Former Rule | Historic; rarely relevant today |
| G | Definitions | Terms such as "establishment" and "health care professional" |
Table: the seven subparts of 29 CFR Part 1904 and what each is for.
If you only have time for one subpart, make it C. That is where the recordability test lives.
Which sections decide whether a case is recordable?
Subpart C is built as a sequence, and the order matters. A case must clear each gate in turn.
- Is it work-related? The work-relatedness rules (1904.5) start from a presumption: if an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a pre-existing one, it is work-related. There are listed exceptions, which we cover in our guide to work-relatedness exceptions.
- Is it a new case? The new-case rules (1904.6) stop you recording the same condition twice.
- Does it meet a general recording criterion? This is 1904.7: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness, plus a significant injury or illness diagnosed by a physician or other licensed health care professional. Our recordable criteria checklist turns that into a working list.
- Does a special rule apply instead? Some situations have their own sections: needlestick and sharps injuries (1904.8), medical removal (1904.9), occupational hearing loss (1904.10) and work-related tuberculosis (1904.11).
The rest of Subpart C covers the forms themselves: the 300 Log, the 301 report and the 300A summary. For a column-by-column walk through the log, see OSHA 300 Log requirements.
Why the first-aid line causes so many mistakes
The medical-treatment trigger in 1904.7 depends on a definition, and that definition includes an exhaustive list of what counts as first aid. If a treatment is on the list, the case is not recordable on that basis alone. If it is not on the list, it is medical treatment. Teams get this wrong in both directions, which is why we wrote a separate comparison of first aid versus medical treatment.
What does Subpart D add?
Subpart D covers the housekeeping that turns individual cases into a compliant recordkeeping system. In practice that means:
- Keeping a separate set of records for each establishment, not one set for the whole company.
- Completing the annual summary, certifying it and posting it from 1 February to 30 April.
- Retaining records for five years after the end of the calendar year they cover, and updating the log during that period if a case changes.
- Involving employees: giving them a way to report injuries and access to the records.
- Prohibiting retaliation against employees for reporting.
Who is partially exempt from OSHA 1904?
Subpart B sets two routes out of routine recording. Employers with 10 or fewer employees are partially exempt, as are establishments in certain low-hazard industries listed in an appendix to the rule. The word "partially" matters: these employers do not keep the 300 Log, but they must still report a work-related fatality, in-patient hospitalisation, amputation or loss of an eye, and they may be asked to take part in OSHA or Bureau of Labor Statistics surveys. We unpack the common traps in partially exempt industries, and our exemptions lookup lets you check a NAICS code.
Common mistakes with OSHA 1904
- Reading only the Log instructions. The form instructions are a summary. The rule text in Subpart C is what an inspector will cite.
- Treating a company as one establishment. The records are kept per establishment, and so are posting and certification.
- Assuming exempt means no duties. Partial exemption removes routine recording, not fatality and severe-injury reporting.
- Confusing work-related with at-fault. Fault is irrelevant to recordability. A case can be recordable even if the employee caused it.
- Guessing when the rule is silent. Where Part 1904 does not settle a case, OSHA's published interpretation letters often do. Our interpretations index collects the ones relevant to recordability.
How Job13 uses Part 1904
Job13's engine applies the federal Part 1904 recording criteria to a case you describe and returns a verdict with the section it relied on. If the facts do not settle the question, it says the case needs review rather than guessing. It covers federal 1904 only; state-plan variations are not handled. You can try it with the free recordability check, or browse the rule text section by section in the rule index.
Frequently asked questions
What does OSHA 1904 mean?
It refers to 29 CFR Part 1904, the federal regulation titled "Recording and Reporting Occupational Injuries and Illnesses". It sets out which workplace injuries and illnesses employers must record, how to complete the forms, and what must be reported to OSHA.
Is OSHA 1904 the same as the OSHA 300 Log?
No. The 300 Log is one form required under Part 1904. The regulation also covers the 301 incident report, the 300A annual summary, the recording criteria, retention periods, exemptions and reporting duties.
Which section of OSHA 1904 says whether an injury is recordable?
Mainly 1904.7, the general recording criteria, applied after work-relatedness (1904.5) and new-case (1904.6) checks. Special rules in 1904.8 to 1904.11 cover needlesticks, medical removal, hearing loss and tuberculosis.
Does OSHA 1904 apply to small businesses?
Employers with 10 or fewer employees are generally partially exempt from routine recordkeeping, as are establishments in certain listed industries. They must still report fatalities and severe injuries, such as in-patient hospitalisations, amputations and loss of an eye.
How long do records under OSHA 1904 have to be kept?
Five years following the end of the calendar year that the records cover. During that time you must update the 300 Log if the classification of a case changes, and provide access to employees and their representatives as the rule requires.
