The Definition of Recordable Incident

Definition of Recordable Incident

A recordable incident is a work-related injury or illness that meets OSHA's criteria for entry on the OSHA 300 Log. Under 29 CFR 1904.7, a case is recordable if it results in death, days away from work, restricted work or transfer to another job, medical treatment beyond first aid, or loss of consciousness. A significant injury or illness diagnosed by a physician or other licensed health care professional is also recordable, even if none of those outcomes occur.

Before applying these general criteria, the employer must decide that the case is work-related and that it is a new case. Under 29 CFR 1904.5, an injury or illness is presumed work-related if an event or exposure in the work environment caused or contributed to it, or significantly aggravated a pre-existing condition, unless one of the listed exceptions applies.

Recordability is about severity and treatment, not fault. A recordable incident does not mean the employer broke a rule, and recording a case is not an admission of a violation.

The General Recording Criteria

Death

Any work-related fatality must be recorded.

Days away from work

• Counting starts the day after the injury occurred or the illness began. The day of injury is not counted.
• Count calendar days, including weekends, holidays and scheduled days off.
• If a physician or other licensed health care professional recommends days away, record them even if the employee comes to work anyway.
• Employers may stop counting at 180 days.

Restricted work or job transfer

A case is a restricted work case when, because of the injury or illness, the employee cannot do one or more routine job functions or cannot work the full workday they would otherwise have worked. Routine functions are activities the employee regularly performs at least once per week. A restriction that applies only to the day of the injury does not make the case recordable.

Medical treatment beyond first aid

Medical treatment means managing and caring for a patient to combat a disease or disorder. It does not include visits only for observation or counseling, or diagnostic procedures such as X-rays and blood tests. First aid is a closed list in 1904.7(b)(5)(ii). It includes:

• Non-prescription medication at non-prescription strength.
• Tetanus immunizations.
• Cleaning, flushing or soaking surface wounds.
• Wound coverings such as bandages, butterfly bandages or Steri-Strips.
• Hot or cold therapy.
• Non-rigid supports such as elastic bandages, wraps and non-rigid back belts.
• Temporary immobilization devices used to transport an injured person.
• Drilling a fingernail or toenail, or draining a blister, to relieve pressure.
• 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.
• Drinking fluids to relieve heat stress.

Anything not on this list is medical treatment, no matter who provides it. For example, a prescription medication, or a non-prescription medication recommended at prescription strength, makes the case recordable.

Loss of consciousness

Any work-related loss of consciousness is recordable, regardless of how long it lasts.

Significant diagnosed injuries and illnesses

Cancer, chronic irreversible diseases, fractured or cracked bones and punctured eardrums must be recorded when diagnosed, even if treatment or restrictions are not recommended.

Separate rules in 29 CFR 1904.8 to 1904.11 cover needlesticks and sharps injuries, medical removal cases, hearing loss and tuberculosis.

Recording and Reporting Requirements

Who must keep records

Employers covered by Part 1904 must keep injury and illness records. Employers with 10 or fewer employees at all times during the previous calendar year, and establishments in certain low-hazard industries listed by OSHA, are partially exempt from routine recordkeeping.

Recording deadlines and forms

• Enter each recordable case on the OSHA 300 Log and complete an OSHA Form 301 incident report within seven calendar days of learning about it (29 CFR 1904.29).
• Post the Form 300A annual summary from February 1 to April 30 each year.
• Keep the 300 Log, 300A and 301 forms for five years.

Recording is not the same as reporting

Some serious events must also be reported directly to OSHA under 29 CFR 1904.39, which applies to all employers covered by the OSH Act, including those exempt from keeping records:

• Fatality: report within 8 hours, if the death occurs within 30 days of the work-related incident.
• In-patient hospitalization, amputation or loss of an eye: report within 24 hours, if it occurs within 24 hours of the incident.

Reports can be made by phone to the nearest OSHA Area Office, to OSHA's toll-free number, or online. See reportable incident for more detail.

Practical Steps for Getting Recordability Right

• Train supervisors to report every injury promptly, so cases can be assessed within the seven-day window.
• Assign one trained person or team to make recordability decisions consistently.
• Get written work restrictions and treatment details from the treating provider.
• Track days away and restricted days until the case closes or reaches 180 days.
• Review the 300 Log for trends and feed the findings into incident investigations and corrective actions.

Example of Recordable Incident

A warehouse worker cut her forearm on a metal strapping band. At the plant's first aid station, the cut was cleaned and closed with Steri-Strips, and she went back to her normal job. Cleaning a wound and applying Steri-Strips are both first aid, so the case was not recordable.

Two days later the wound reopened and she went to an urgent care clinic, where the provider closed it with stitches. Stitches are medical treatment beyond first aid, so the employer recorded the case on the 300 Log and completed a Form 301 within seven days of learning about the clinic visit. Because there was no fatality, in-patient hospitalization, amputation or loss of an eye, the case did not have to be reported to OSHA.

Frequently Asked Questions: Recordable Incident

What is the difference between a recordable incident and a reportable incident?

A recordable incident meets OSHA's criteria for entry on the 300 Log as part of routine recordkeeping. A reportable incident is a fatality, in-patient hospitalization, amputation or loss of an eye that must be reported directly to OSHA within 8 or 24 hours. Most reportable incidents are also recordable.

Does first aid count as a recordable incident?

No. Treatments on OSHA's first aid list, such as bandages, non-prescription medication at non-prescription strength and cold packs, do not make a case recordable on their own. Only treatment beyond that list counts as medical treatment.

Who decides whether an incident is recordable?

The employer, usually through trained EHS or HR staff, applying the criteria in 29 CFR 1904. A health care provider's recommendations about treatment, restrictions and days away are key inputs, but the recordkeeping decision belongs to the employer.

What happens if a company fails to record a recordable incident?

OSHA can issue citations and penalties for recordkeeping violations found during an inspection. Missing cases also distort injury data and make it harder to spot and fix real hazards.

How do recordable incidents affect a company's safety rate?

Recordable cases are used to calculate the total recordable incident rate: the number of recordable cases multiplied by 200,000, divided by total hours worked. Many clients ask contractors for this rate when they prequalify them for work.