The OSHA Recordable Criteria Explained

The Occupational Safety and Health Administration (OSHA) recordkeeping guidelines are a necessary evil — they exist to make sure that workplace safety is properly monitored. But, sometimes, understanding all the rules and exceptions just results in a massive headache. 

This OSHA recordability guide is here to prevent that headache (which by the way, is not an OSHA recordable incident) and ensure that you know everything you need to know about OSHA recordable criteria to keep you out of trouble!

We will tell you exactly which accidents should be reported in your safety records and which don’t need to be. We will also talk about the related regulations that you need to follow. So, let’s hop right in.

What Is An OSHA Recordable?

As an employer, OSHA requires you to prepare and maintain records of serious occupational injuries and illnesses, called, for short, “OSHA recordables”. This could include a range of conditions that result in any of the following:

• A work-related fatality. 
• Loss of consciousness (unless caused by a pre-existing illness such as epilepsy). 
• Any significant injury or illness diagnosed by a licensed health care professional as work-related (e.g., cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum). Such cases must be recorded at the time of diagnosis. 
• Any time off work after the day that the injury occurred. 
• Restricted work or a job transfer as a result of a work-related injury. Restriction occurs when the employee is unable to perform their routine functions, i.e. work activities performed at least once a week.
• Medical treatment of work-related incidents beyond first aid. 

Any condition that falls into one of these categories must be recorded on a Form 300 which serves as a log of work-related injuries and illnesses. 

Special recording criteria apply to needlestick and sharps injury cases, tuberculosis cases, hearing loss cases, and medical removal cases. 

Determination of work-relatedness

An illness or injury is considered work-related if there was an event or exposure in the work environment which was responsible for the resulting condition. Work-relatedness can also apply if a pre-existing injury or condition was aggravated due to an event or exposure.

Under paragraph 1904.5(b)(2)(iii), OSHA allows the employer to refute the presumption of work relationship if “the injury or illness results solely from voluntary participation in a wellness program or in a medical, fitness, or recreational activity such as blood donation, physical, flu shot, exercise class, racquetball, or baseball.”

So, if the employee were to faint during a voluntary program, this would not be an OSHA recordable event. But, if they were to faint during one of the mandatory medical procedures such as blood tests, this would be considered a work-related event and the case would be recordable for OSHA recordkeeping purposes.

For additional information, see the OSHA General Recordability Criteria (Standard 1904.7).  

OSHA Recordable Criteria

Who should post OSHA 300 logs (and who is exempt)?

If your organization has more than ten employees or belongs to an industry that demonstrates a high rate of hazardous incidents, then you are subject to the OSHA rules and you may need to submit your records online. 

If you had less than ten employees in the previous calendar year and you are in one of the low-hazard industries, you are exempt from keeping track of injuries and sickness, according to OSHA Standard 1904.7.

Sidenote OSHA recently published a Final Rule amending its recordkeeping regulation. It states that all organizations with 250 or more employees are required to submit their OSHA 300 and 301 forms electronically.

OSHA Recordable Decision Tree

To record or not to record is a common dilemma most employers face. There are quite a few gray areas with illness and injury recordkeeping. And it’s often difficult to analyze if an injured employee’s case meets the required criteria or not.

So how are you supposed to tell the difference? Well, the United States Department of Labor has been so kind as to provide us with an OSHA recordable decision tree. This simple tool can give you a basic understanding of how the accident reporting process works and if you even have to report an incident or not. 

• First, analyze if the employee has actually suffered an injury or illness. If yes, determine if the injury or illness is work-related? 
• If yes, is this injury or illness a new case? If yes, then go ahead and check if the illness or injury meets the general recording criteria. 
• If yes, it is an OSHA recordable injury or illness. 

OSHA Recordable Vs. Reportable Events

All incidents that meet the recording criteria need to be reported on Form 300. But there are 4 very specific cases that must be reported to the government within a predefined time-frame. These are:

1. The loss of an eye. 
2. Any form of amputation 
3. Hospitalization of an employee (in terms of needing to stay in the hospital to receive treatment)
4. Any work-related fatality of any kind. 

In all of these cases, you are required to report to OSHA via phone call or an online form. 

These types of incidents need to be reported within 24 hours of you becoming aware of them, except for the fatalities. The fatality reporting must be done within 8 hours of the death being discovered either following a work-related accident or in-patient hospitalization. This is to ensure that a safety inspection can be done at the workplace as soon as possible.

In the event that you need to report an incident, you have 1 of 3 options:

WHAT DO I DO?	HOW DO I DO IT?
Call your nearest OSHA Area Office	The link will take you to a map so that you can choose your location and get the right number.
Call the OSHA 24-hour hotline	1-800-321-6742
Report the incident online	https://www.osha.gov/pls/ser/serform.html

You can have a deeper look at the reportability guidelines here in the OSHA 1904.39(b)(6).

Special cases 

Another major factor to remember while determining an OSHA recordable incident is that it needs to be through exposure or an event in the workplace that resulted or caused the recordable injury or death during work hours. If this is not met, the incident is not reportable. 

Also note that, if the in-patient care of the patient only lasts for an observation, then the incident is only recordable but not reportable. For example, if a worker fell during work hours, was admitted to the hospital, and kept for an observation but released on the next day, this is considered a non-reportable accident.

If you are still unsure of what constitutes an OSHA reportable and recordable incident, the best way forward is to contact the agency and ask for clarification.

You can also see the OSHA reporting requirements for more information or clarification.

OSHA Recordable Events Vs. First Aid Incidents

We know that recordable events involve any medical treatment required beyond first aid. The problem comes in with the fact that your definition may differ than OSHA’s. You may think that the treatment provided falls under that category, but according to OSHA regulations, it was actually a recordable injury, and vice versa. 

First aid includes the following conditions:

• Normal treatment with non-prescription medication at a non-prescription strength.
• Tetanus shots or other vaccines administered at the workplace.
• Cleaning surface wounds.
• Using bandages, band-aids, gauze pads, butterfly bandages, etc.
• Using hot or cold therapy.
• Use of non-rigid means of support such as elastic bandages, wraps, or any other non-rigid support structure.
• Using devices that temporarily immobilize the worker, such as slings, splints, neck, and backboards.
• Draining blisters or nails to eliminate pressure.
• Eye patches.
• Removing foreign substances from the eye through only flushing or swabs.
• Eliminating foreign material from the body such as splinters, from any other body parts other than the eye.
• Utilizing massages that are not part of chiropractic treatment or physical therapy.
• Replenishing fluids to relieve symptoms of heat stress.

You can find all conditions considered to be first-aid incidents by OSHA in this list.

Sidenote It’s obviously a bad idea to underreport incidents but it’s also a bad idea to overreport. Not only will your company be cited with a violation of the OSHA rules, but your incident rate will be artificially inflated, which means that you’ll be higher up on the list for inspections.

Examples of Recordable Events 

Recordable	Non-Recordable
Visiting healthcare professionals for non-first aid treatments.	Conditions treated with first aid.
Cuts, lacerations, abrasions, and puncture wounds requiring sutures, staples, medical glue, disinfectant, and surgical cleaning.	Normal cleaning, bandaging, band-aid, non-rigid support.
Inoculations needed for specific treatment for work-related injuries.	Vaccination, immunization, tetanus shot given for public health, or other reasons.
Oxygen administered in injuries or sickness.	Oxygen administered as a precautionary measure.
Loss of consciousness due to chemical, gas, heat, injury, or accident at the workplace.	Loss of consciousness due to epilepsy, narcolepsy, diabetes, or any other personal health issue.
Splinters that cannot be removed with simple means due to the place of injury, depth, shape, or size.	Splinter removed from the body through tweezers, needles, small tools, cotton swabs from any part of the body other than the eye.Removing splinters or foreign bodies from the eye only through irrigation or cotton swab.
Dislocations or strain sustained requiring a rigid support system, chiropractic therapy, physical therapy recommended by a licensed physician.	Normal hot or cold therapy administered at the workplace, usage of non-rigid support such as bandages, wraps, etc. Using temporary devices causing immobilization, including slings, splints, neck, and backboards.
Bruises or contusions received through needles during bruise draining.	Using nonprescription drugs to treat any injury.

Speaking of this, you may also be interested in these example incident reports for the workplace.

OSHA’s Recordable Incident Forms 

Here are the three forms that you need to fill out:

• OSHA Form 301 (Injury and Illness incident report)

You must fill up this form in case of each incident that is recordable within seven days of the occurrence. This form provides details about the injured worker and the nature of the incident.

• OSHA Form 300 (Log of Work-Related Injuries and Illnesses) 

This form keeps a log of all the recordable incidents that happened in the past calendar year and must be submitted on an annual basis. It captures the most vital elements of Form 301. The purpose of the form is to help OSHA assess if the facility has adequate safety measures.

• OSHA Form 300A (Summary of Work-Related Injuries and Illnesses)

This form is a dashboard for reporting all the recordable incidents for each year. It includes details like the total number of reportable accidents, how many days of work were lost, and the type of incidents. The purpose is to capture the incident rate through various OSHA accident reports. The calendar year begins in April and ends in February. 

You must also provide transparent access to workers to the Forms 300, 300A, and some parts of Form 301, according to OSHA 1904.35.

What Is the Total Recordable Incident Rate (TRIR)?

TRIR is the number of recordable incidents of a company in a calendar year. OSHA tracks this number to determine safety performance and decide if they should pay you a visit. Here’s an easy guide to TRIR calculation in case you need it. 

What is the Days Away From Work Restricted or Transferred (DART) rate?

DART stands for the Days Away, Restricted or Transferred rate. It’s a lagging indicator Like TRIR and LTIR. DART is tracked by OSHA because it gives an insight into your incidence rate and the level of impact incidents have on your operations. 

OSHA Recordable FAQs

Q: What are the 4 on-the-job incidents that require you to make a report directly to OSHA by phone or online?
A: The loss of an eye, amputation, hospitalization and any work-related fatality.  

Q: Are restrictions OSHA recordable?
A: A work restriction is only recordable if it affects the employee’s routine job functions. 

Q: Is a finger splint OSHA recordable?
A: Yes, always, as a splint is always considered medical treatment. 

Q: Is a prescription an OSHA recordable?
A: Yes, as they are considered medical treatment. 

Q: Is loss of consciousness considered an OSHA recordable event?
A: Yes, unless caused by a pre-existing condition such as epilepsy.

Q: Is COVID-19 an OSHA recordable?
A: OSHA’s new updated OSHA recordkeeping requirements list COVID-19 as a recordable sickness, and this means you are responsible for keeping a record of OSHA recordable COVID-19 cases in the following situations:

• The employee has a confirmed case of COVID-19.
• The case is a work-related sickness. You can find more details in guideline 1904.5.

Q: Is “Light Duty” a Recordable Restriction?

A: OSHA’s recordkeeping regulation, section 1904.7(b)(4)(vii), indicates that “light duty” may need to be recorded as a restriction.  In such cases, the physician must explicitly be asked “whether the employee can do all of his or her routine job functions and work all of his or her normally assigned work shift.” If the answer to one or both questions is No, then this must recorded as a restricted work case. 

Q: How Do You Count Restricted Work Days?

A: Days of job transfer or restrictions are counted just like days away from work, using (see 1904.7(b)(3)(i) to (viii)). Both weekend days and weekdays count. The difference is when you permanently assign the injured or ill employee to a job that has been modified or permanently changed. If the employee is not performing his or her routine functions on the new job, you may stop the day count.

References & Further Reading

• OSHA Recordable Decision Tree
• OSHA Revised Enforcement Guidance Featuring COVID-19
• OSHA – Employee Involvement
• OSHA Injury and Illness Recordkeeping Requirements
• OSHA General Recording Criteria
• Concentra – What Employers Need To Know About OSHA Recordables
• Guide To OSHA Recordable Injuries And Illnesses