A forklift clips a pallet, a strap snaps back, and a warehouse supervisor is left holding an incident report fifteen minutes later, trying to work out whether it goes in the OSHA 300 Log. Get it wrong one way and you under-report — a real problem in an inspection. Get it wrong the other way and your Total Recordable Incident Rate creeps up for a case that never needed to count. Neither is a guess you want to make twice.
"OSHA recordable" has a precise legal meaning under 29 CFR Part 1904, the federal recordkeeping rule. It is not the same as "an accident happened" and it is not the same as "OSHA needs to know about this" — that's a separate, narrower duty called reportability, which we cover in our piece on recordable vs reportable injuries. This guide walks through the actual test the rule sets out, in the order it sets it out, with the section numbers attached so you can check our working.
What "OSHA recordable" actually means
A work-related injury or illness is recordable when it meets any one of the criteria set out in 29 CFR 1904.7 — the general recording criteria — and it clears two gates first: it happened in the work environment (work-relatedness, 1904.5) and it's a new case rather than a flare-up of an old one (1904.6). Meet all three and the case goes in the OSHA 300 Log; miss any one and it doesn't, unless privacy or a partial exemption changes how it's logged.
That's the whole shape of the rule. Everything else — the fourteen-item first aid list, the nine work-relatedness exceptions, the six privacy case categories — exists to answer edge cases within that shape, not to replace it. We built Job13's recordability check to run exactly this sequence and show the citation behind each step, because doing it from memory is where mistakes creep in.
The three-part test, in order
1. Did it happen in the work environment?
1904.5(a) presumes work-relatedness for anything that happens in the work environment, defined broadly as any place, or the equipment or materials in it, that the employer's business operations bring the employee into. You don't have to prove the job caused it — the presumption runs the other way, and the employer has to show one of nine specific exceptions applies to rule it out.
The nine exceptions in 1904.5(b)(2) cover things like: the employee was present only as a member of the public, symptoms surfaced at work but came from a non-work event, the case involves eating or drinking for personal consumption, personal grooming or self-medication, the common cold or flu, or a motor vehicle accident in a parking lot while merely commuting. We go through all nine, with the exact regulatory wording, in our work-relatedness deep dive.
Worked example. An employee twists an ankle playing in the company softball game after work. Was that "the work environment"? Usually not — voluntary participation in a recreational activity is one of the nine exceptions (1904.5(b)(2)(iii)), so the case clears the work-relatedness gate as not work-related and stops there. Change one fact — the game was mandatory, or played on a lunch break the employer required — and the analysis can flip.
2. Is it a new case?
1904.6 asks whether this is a new case or a continuation of one already recorded. A case is new if the employee has never had a recorded injury or illness of this type before, or if they'd fully recovered from a prior one (all signs and symptoms gone) and an independent event at work caused it again. A flare-up of an existing, unresolved condition — chronic back pain that gets worse on a particular day, say — generally isn't a new case on its own; it may instead be an update to the existing entry.
This gate exists because without it, a single ongoing condition could generate a fresh log entry every time it acted up, which would inflate the log and misstate your incident rate.
3. Does it meet a 1904.7 recording criterion?
This is where most of the actual judgement happens. A work-related, new case is recordable if it results in any one of the following:
| Criterion | Section | What it covers |
|---|---|---|
| Death | 1904.7(b)(2) | Any work-related fatality, however delayed |
| Days away from work | 1904.7(b)(3) | The employee couldn't work at all for one or more days after the day of injury |
| Restricted work or job transfer | 1904.7(b)(4) | The employee was kept from doing their routine job functions, or moved to another job |
| Medical treatment beyond first aid | 1904.7(b)(5) | Treatment given falls outside OSHA's 14-item first aid list |
| Loss of consciousness | 1904.7(b)(6) | Any work-related loss of consciousness |
| Significant injury or illness | 1904.7(b)(7) | A physician or licensed health care professional diagnoses a significant injury or illness — cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum, for example — even without meeting any other criterion |
Meeting any one of these is enough. A cut that needed nothing more than a plaster (first aid) but also kept someone off their normal duties for a shift is recordable — not because of the treatment, but because of the restricted work.
The two criteria that cause the most disagreement
Medical treatment vs first aid. OSHA's first aid list is exhaustive and closed — fourteen items, and nothing else counts as first aid, however minor it looks in practice. Prescription-strength ibuprofen given at prescription strength is medical treatment even if a pharmacist would wave it through without a second thought; the same drug at non-prescription strength is first aid. Sutures are medical treatment; a butterfly bandage or Steri-Strip is first aid. We've written the full fourteen-item list, with the version most published summaries get wrong, in first aid vs medical treatment, explained.
Restricted work. A case is restricted work if the employee's normal job functions are curtailed for any part of a day because of the injury — moved to a job that pays the same but does something different, given lighter tasks, or told not to complete part of their normal role. It doesn't need a doctor's note to count, and "we sent them home to rest just in case" is very often restricted work in substance even when nobody used that word out loud.
A quick anecdote from the log
One pattern we see constantly in the scenarios we've worked through building the recordability engine: two nearly identical cuts, two different outcomes, because one employee went back to their normal shift and the other was put on light duty "for a day or two, just to be safe." The medical treatment was identical — a wound closure, no prescription. The first case is not recordable under any criterion. The second is, purely on the restricted-work criterion, the moment someone changed that employee's normal duties. The regulation doesn't care that the restriction was well-intentioned caution rather than a doctor's order — 1904.7(b)(4) is triggered by the restriction itself.
What happens once something is recordable
A recordable case gets an entry on the OSHA 300 Log — case number, a brief description, the classification (death, days away, restricted/transfer, or "other recordable case"), and the day counts. At year end, those entries roll up into the 300A summary, which is what gets posted 1 February–30 April and, for many establishments, submitted electronically through OSHA's Injury Tracking Application by 2 March. We cover that pipeline end to end in the OSHA 300 Log explained and OSHA 300A posting requirements.
Common pitfalls
- Treating "no lost time" as "not recordable." Restricted work and medical-treatment-beyond-first-aid trigger recordability with zero days away from work.
- Letting the treatment given decide the case, rather than the treatment that was medically necessary. If a physician recommends sutures and the employee declines, OSHA still typically treats the case as though the recommended treatment was given.
- Missing the "one criterion is enough" rule. Teams sometimes look for the worst applicable criterion and stop if the case seems minor overall, missing that a lesser but still-qualifying criterion (like restricted work) already settled it.
- Forgetting privacy cases still get logged. A privacy concern changes how a case is described on the log — the employee's name is replaced with "privacy case" — not whether it's logged at all.
FAQ box: the short answers
Is a case with no missed work still recordable? Yes, if it meets restricted work, medical treatment beyond first aid, significant diagnosis, loss of consciousness, or death — none of those require missed work.
Does "recordable" mean OSHA has to be called? No. Recordable means it goes in your own OSHA 300 Log. Reporting is a separate, narrower duty — see recordable vs reportable.
What if the facts are genuinely unclear? Say so. Job13's engine returns needs review rather than guessing whenever the rule leaves a judgement call open — that's a more honest answer than forcing a yes/no on facts the regulation itself doesn't resolve.
Frequently asked questions
What is the OSHA recordable definition in one sentence?
A work-related injury or illness is OSHA recordable when it's a new case that meets at least one of the 1904.7(b) criteria — death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosis by a physician.
Does every workplace injury have to be recorded?
No. Only injuries and illnesses that are work-related, new, and meet a 1904.7 criterion are recordable. A minor cut treated only with a plaster, with no restricted work and no missed time, is not recordable — it stays first aid.
Who decides if a case is OSHA recordable?
The employer makes the determination, using the criteria in 29 CFR 1904.7. There's no OSHA sign-off required beforehand; the employer's own recordkeeper applies the test, keeps the 300 Log, and is the one an inspector checks against it later.
Is first aid treatment ever recordable?
Treatment that stays within OSHA's fourteen-item first aid list does not, by itself, make a case recordable. But the same case can still be recordable on a different ground entirely — restricted work or days away, for instance — even when the treatment given was first aid.
Do OSHA-exempt industries still have to determine recordability?
Partially exempt industries under Appendix A generally don't have to keep routine OSHA 300 Logs, but they must still record any work-related fatality, hospitalisation, amputation, or loss of an eye if OSHA or the BLS requests it in writing. We cover the trap this creates in partially exempt industries.
