OSHA Recordable Criteria: The Full 1904.7 Checklist

A machine operator gets a laceration from a jammed conveyor, gets it cleaned and steri-stripped at urgent care, and is back on the line the same afternoon. Is that OSHA recordable? You can't answer with a guess, and you shouldn't have to reread the whole of Part 1904 every time someone asks. The osha recordable criteria in 29 CFR 1904.7(b) are a short, ordered list — six triggers, and hitting any one of them is enough. This is that list, in the order to run it, with the section number for each stop.

How to use this checklist

Work through the six criteria below in order and stop at the first one the case hits. You don't need to check all six — you need the first one that's true. Before you start, the injury or illness has to have already cleared two earlier gates: it's work-related under 1904.5, and it's a new case rather than a flare-up of something already on the log (1904.6). If either of those fails, you never reach this checklist at all. Assuming both gates are clear, here's the sequence.

The six criteria, one line each

This table shows all six 1904.7(b) recording criteria in the order OSHA lists them, with the specific fact that triggers each one.

Now the detail behind each row, because the wording matters and each one has a habit that trips people up.

1. Death — 1904.7(b)(2)

Any work-related death is recordable, full stop, no threshold, no judgement call. It doesn't matter if it happens on the day of the incident or months later — if a work-related injury or illness eventually causes death, it goes on the log. A death also triggers a separate duty: report it to OSHA directly within 8 hours under 1904.39. Recording and reporting are two different obligations that happen to overlap here — we cover the difference in recordable vs reportable injuries.

2. Days away from work — 1904.7(b)(3)

This one is about calendar days, not shifts, and counting starts the day after the injury happened, not the day it happened. If someone gets hurt on a Tuesday and can't come in Wednesday, that's one day away. The count runs in calendar days including weekends, and it caps at 180 days — you don't have to keep counting past that even if the person is still out. We walk through the counting mechanics, including the weekend and holiday edge cases, in the 180-day rule for days away from work.

3. Restricted work or job transfer — 1904.7(b)(4)

This is the criterion people miss most often, because the employee is still at work. If a doctor says "no lifting over 10 lbs" or "light duty only" and the employee can't do one or more of their routine job functions as a result, that's a restriction — recordable, even though nobody took a day off. Same goes for a temporary transfer to a different job to accommodate the injury. The test isn't whether the person felt fine; it's whether their normal duties were actually curtailed.

4. Medical treatment beyond first aid — 1904.7(b)(5)

This is where most disputes happen, because "first aid" isn't a judgement call under the rule — it's a closed list of 14 specific items. If the care given matches something on that list, it's first aid and not recordable on this criterion alone. If it doesn't — sutures, prescription-strength medication, physical therapy, X-rays that reveal a fracture — it's medical treatment, and the case is recordable. We keep the full 14-item list, with the exact regulatory wording, at first aid vs medical treatment, and the underlying logic in our first aid vs medical treatment blog post.

5. Loss of consciousness — 1904.7(b)(6)

Any work-related loss of consciousness is recordable, no matter how brief. A momentary faint from heat exposure counts the same as a longer episode. There's no minimum duration written into the rule, and there's no judgement call to make here — if consciousness was lost and the case is work-related, it's recordable on this criterion alone.

6. Significant injury or illness diagnosed by a physician or licensed health care professional — 1904.7(b)(7)

This is the catch-all, and it exists specifically for cases that wouldn't otherwise trigger anything above. OSHA names cancer, chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum as examples of "significant" — diagnosed by a physician or other licensed health care professional, even if the person never missed a day, was never restricted, and got no more than first aid. A hairline fracture found on an X-ray, with the employee back to full duty the next day, still lands here.

A worked example

A warehouse picker named on the incident report as "Employee, Order Picker" steps off a pallet jack and rolls an ankle. Nothing seems broken. The site nurse sends her to urgent care as a precaution. X-rays come back clean, but the physician diagnoses a moderate ankle sprain, gives her a compression wrap, and writes "light duty, no walking routes over 500 ft, for five days." She's back the next morning on a modified role checking inbound pallets from a stool.

Run the checklist. No death, no days away — she never missed a shift. Criterion 3 hits first: the "light duty" restriction stopped her doing her normal picking route, so this is recordable under 1904.7(b)(4), restricted work. It doesn't matter that the compression wrap itself would count as first aid under the list — the case is already recordable before you'd even reach criterion 4. That's the value of running the list in order: you stop at the first hit and don't need to argue the rest.

Where teams get this wrong

• Treating restricted work as "she's fine, she's at her desk." Restriction is about duties, not attendance. An employee sitting at their normal desk who can't lift, climb, or drive as part of their job is still restricted if those tasks are part of their routine work.
• Assuming any doctor visit is automatically medical treatment. A visit alone isn't the test — what happened during it is. A physician who only cleans a wound and applies a bandage delivered first aid under the 14-item list, even though it happened in a clinic.
• Missing (b)(7) because nothing "big" happened. A diagnosed fracture with zero days away and zero restriction still clears the bar. Teams that stop checking once days-away and restricted-work come back negative miss this one regularly.
• Confusing recordable with reportable. Every fatality and certain hospitalisations, amputations, and eye losses must be phoned or logged to OSHA directly under 1904.39 — a separate, faster-moving duty from the 300 Log entry. See recordable vs reportable OSHA for the full split.
• Forgetting the two gates before criterion 1. A case can hit "days away" cleanly and still not belong on the log if it fails work-relatedness under 1904.5 or isn't a new case under 1904.6. The six criteria only apply to cases that already cleared both.

How does restricted work differ from days away from work under OSHA?

Days away from work means the employee could not perform their job at all for at least one calendar day. Restricted work means the employee returned or stayed on the job but couldn't do one or more routine functions, or was moved to a different role, because of the injury. Both are recordable under separate criteria — 1904.7(b)(3) and 1904.7(b)(4) — and a single case can start as one and convert to the other as the person's condition changes.

Does a hospital visit automatically make an injury OSHA recordable?

Not by itself. What matters is the treatment given, not the setting. A hospital or urgent care visit that only delivers care from the 14-item first aid list — cleaning a wound, an ice pack, a bandage — doesn't trigger criterion 4 on its own. Treatment beyond that list, in any setting, does. Separately, an in-patient hospitalisation triggers its own OSHA reporting duty under 1904.39, which is not the same test as recordability.

What counts as "significant" under the diagnosis criterion?

OSHA gives examples rather than a fixed definition: cancer, a chronic irreversible disease, a fractured or cracked bone, and a punctured eardrum. The common thread is a diagnosis from a physician or licensed health care professional that describes a real, lasting condition — even one that produces no days away and no restriction. When a diagnosis doesn't obviously match those examples, this is exactly the kind of judgement call OSHA leaves to the employer, and it's one of the places where a documented "needs review" flag is more defensible than a rushed yes or no.

The osha recording criteria in 1904.7(b) look simple written out as six bullet points, and mechanically they are — but a fair amount of the real work is applying the closed first aid list correctly and recognising a restriction that doesn't look like one on paper. "The hardest cases aren't the dramatic ones," one EHS manager we spoke with put it. "It's the guy who's back at his desk the next day on modified duties. Everyone assumes fine means not recordable, and that's exactly where (b)(4) catches you." OSHA's most recent Injury Tracking Application submissions show restricted work and days-away cases still make up a large share of what gets logged industry-wide, which tracks with how often that specific criterion gets missed in practice.

Run an actual case through this checklist at Job13's free recordability check — it walks the same six criteria in the same order, cites the section behind each answer, and returns "needs review" rather than forcing a guess when the rule leaves room for judgement. Paying users can also keep the resulting 300 Log, 300A summary, and ITA export in one place. This is not legal advice; check OSHA's recordkeeping guidance or an EHS professional for a case that stays genuinely unclear.

Frequently asked questions

What are the six OSHA recordable criteria under 1904.7(b)?

They are: death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, and a significant injury or illness diagnosed by a physician or licensed health care professional. Meeting any single one makes a work-related, new case recordable — you don't need to meet more than one.

Do I need to check all six criteria for every case?

No. Check them in order and stop at the first one the case meets. If a case involves days away from work, it's already recordable under 1904.7(b)(3) and you don't need to also evaluate medical treatment or the significant-injury catch-all.

Is first aid ever enough to make a case OSHA recordable?

Not on its own. First aid is a specific, closed list of 14 treatments under 1904.7(b)(5)(ii). A case that only receives first aid, and meets none of the other five criteria, generally isn't recordable. See our full first aid list for exactly what's included.

What is the difference between OSHA recordable and OSHA reportable?

Recordable means the case goes in the OSHA 300 Log under the 1904.7 criteria discussed here. Reportable means a fatality or certain hospitalisations, amputations, or eye losses must be reported directly to OSHA under 1904.39, separately from and often faster than the annual log. A case can be reportable, recordable, or both.

Where can I check the exact regulatory wording for these criteria?

The full text of 1904.7 is at Job13's copy of the rule and at OSHA's official regulation page, which mirrors the eCFR text of Part 1904.