An injury is OSHA-recordable when it is work-related and results in death, days away from work, restricted duty or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant injury diagnosed by a licensed health care professional. If the only care given falls within the closed list of treatments in 29 CFR 1904.7(b)(5)(ii) — bandages, hot or cold therapy, tetanus shots, non-prescription medication at non-prescription strength, and the eleven other items — the case stays off the 300 Log.
That single distinction drives every recordkeeping decision a safety manager makes. Get it wrong, and you either inflate your DART rate by logging first-aid cases that should not have been recorded, or you miss a recordable and walk into an OSHA citation. This article walks the decision flowchart line by line, with the specific tests OSHA inspectors apply.
Is the Injury Even Work-Related?
Work-relatedness is the first gate, and it is broader than most managers assume. Under 29 CFR 1904.5, an injury or illness is presumed work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated a pre-existing condition. The work environment includes any location where one or more employees are working or are present as a condition of their employment — a job site, a customer’s facility, a parking lot the employer controls, a hotel room while traveling on business.
Nine narrow exceptions break the presumption. The most-cited ones at OSHA compliance audits are: the injury was self-inflicted, the employee was eating or preparing food for personal consumption, the employee was at the establishment as a member of the general public rather than as an employee, and signs and symptoms of a previously diagnosed condition surfaced at work without any workplace contribution. If none of those nine exceptions applies, the case is work-related — full stop.
Travel rules are where many safety managers stumble. An injury during business travel is work-related the entire time the employee is on travel status, except when the employee is in a personal capacity (sightseeing, visiting friends) or temporarily checked into a permanent residence. A slip-and-fall in a hotel lobby on the way to a client meeting is work-related. The same slip on the way back from a movie theater is not.
What Counts as “Medical Treatment Beyond First Aid”?
OSHA published an exhaustive 14-item list of what counts as first aid under 29 CFR 1904.7(b)(5)(ii). Anything not on that list and provided as medical care triggers a recordable. The list is closed — meaning OSHA does not allow analogies. If the treatment is not on the list, it is medical treatment, even when a licensed nurse provides it.
The 14 first-aid treatments are: using non-prescription medication at non-prescription strength, administering tetanus immunizations, cleaning, flushing or soaking wounds on the skin surface, using wound coverings such as bandages or gauze pads, using butterfly bandages or Steri-Strips (sutures and staples are medical treatment), using hot or cold therapy, using non-rigid means of support such as elastic bandages or non-rigid back belts, using temporary immobilization devices while transporting an accident victim, drilling a fingernail or toenail to relieve pressure or draining fluid from a blister, using eye patches, removing foreign bodies from the eye using only irrigation or a cotton swab, removing splinters from anywhere other than the eye by irrigation or simple means, using finger guards, and drinking fluids for relief of heat stress.
Three lines get crossed most often. A prescription written by a physician — even if the employee never fills it — is medical treatment and is recordable. Physical therapy and chiropractic adjustments are medical treatment; the only “massage” that counts as first aid is informal rubbing, not anything billed as therapy. Sutures, staples, or surgical glue are medical treatment, even on a quarter-inch cut. Coggno’s OSHA Recordkeeping: General Recordkeeping Criteria course walks supervisors through these calls in 45 minutes with worked examples.
How Do You Apply the Decision Flowchart in Under 60 Seconds?
Every recordable determination should run through five sequential questions. Stop at the first “no” — that ends the analysis.
Question 1: Did an event or exposure in the work environment cause, contribute to, or significantly aggravate the injury or illness? If no, not recordable. If yes, continue.
Question 2: Does one of the nine 1904.5(b)(2) exceptions apply (personal task, eating, member of the public, signs of pre-existing condition at work without contribution, mental illness without a licensed-professional opinion, common cold or flu, recreational on-site activity outside of work, food or drink for personal consumption, intentional self-inflicted injury)? If yes, not recordable. If no, continue.
Question 3: Did the case result in death, days away from work, restricted work or job transfer, or loss of consciousness? If yes, record. If no, continue.
Question 4: Was the treatment limited to items on the 14-item first-aid list in 1904.7(b)(5)(ii)? If yes, not recordable. If no, continue.
Question 5: Was the case diagnosed by a licensed health care professional as a significant injury or illness (punctured eardrum, fractured or cracked bone or tooth, cancer, chronic irreversible disease)? If yes, record even with no other criteria met. Otherwise, the recordable test rests on whatever criterion in questions 3 or 4 was triggered.
Coggno’s OSHA Recordkeeping & Documentation module reinforces this five-step workflow with practice scenarios pulled from real OSHA letters of interpretation, and a complete walk-through of the OSHA 300 Log entry process once recordability is confirmed.
What About Restricted Duty and Days-Away Counting?
Restricted duty triggers a recordable just as squarely as days away. OSHA defines restriction as the employee being kept from performing one or more of the routine functions of his or her job, or from working the full workday he or she would otherwise have worked. Routine functions are work activities the employee performs at least once a week. A licensed health professional’s written recommendation to restrict counts; so does the employer’s own decision to put the employee on light duty.
The day of the injury itself never counts toward the days-away or restricted total — counting starts on the calendar day after. Weekends, holidays, vacation days, and scheduled days off all count if the restriction or absence spans them. The maximum cap is 180 days for any single case, after which you stop counting and enter 180 in either column G or column H of the 300 Log.
A short restricted-duty period without separate medical treatment is still recordable on its own. If a supervisor sends a worker home for the rest of the shift after a near-miss but the worker returns the next day fully capable, the day-of restriction does not in itself trigger a recordable — but if the next-day return is to modified duty for any portion of the next scheduled shift, that calendar day counts as restricted and the case is recordable. The incident investigation notes you collect in the first hour determine how this gets coded.
What Are the Privacy-Concern Cases That Stay Off the Main 300 Log?
Six categories of cases require entries on the 300 Log but with the employee’s name replaced by “privacy case” in column B: injuries or illnesses to an intimate body part or reproductive system, sexual assault, mental illness, HIV/hepatitis/tuberculosis, needlestick injuries and cuts from sharps contaminated with another person’s blood, and any other illness if the employee independently requests privacy.
Privacy cases still count toward the establishment’s incidence rate, DART rate, and OSHA Form 300A annual summary. The employer keeps a separate confidential list mapping case numbers to employee names — accessible to the employer, the employee, and OSHA, but not to other employees or the general public. State workers’-compensation systems often require the name on their forms, and that disclosure does not change the federal privacy treatment of the 300 Log entry.
What Does Coggno’s Recordkeeping Library Cover for Safety Teams?
Coggno’s marketplace stocks four OSHA recordkeeping courses purpose-built for safety managers and supervisors who own the recordable-vs-first-aid call. OSHA Recordkeeping and Reporting: 300 Forms walks line-by-line through the Form 300, 300A, and 301; it pairs well with OSHA Recordkeeping and Reporting: 300 Forms (alt edition), which adds inspector-perspective audit drills. The general criteria module above covers the work-relatedness, first-aid, and restricted-duty tests. Slips, Trips & Falls handles the category that drives the largest share of recordable cases in office, warehouse, and retail environments. Buyers can pre-assign all four to safety supervisors through Coggno’s LMS or deliver them as SCORM 1.2 / 2004 packages into an existing LMS through Course Dispatch.
Where standalone safety-content vendors price OSHA recordkeeping courses by the seat per course, Coggno bundles the full recordkeeping series — plus 10,000+ additional compliance courses — into a flat $5/user/month Prime subscription with a 14-day free trial. Documented training timestamps roll into Coggno’s audit-ready exports formatted for OSHA-300 review, the same documentation Coggno’s incident reporting and injury and illness prevention program guides reference as the documentation backbone OSHA inspectors expect.
Why Coggno for OSHA Recordkeeping Documentation
For OSHA-regulated employers managing 100–5,000 workers across one or more establishments, Coggno provides OSHA-Authorized OSHA 10 and OSHA 30 courses (general industry and construction) delivered through content partner PureEHS as listed on osha.gov, plus the recordkeeping-specific course series referenced above — all inside a flat $5/user/month subscription with a 14-day free trial. Audit-ready training records formatted for OSHA review export in one click, and Course Dispatch delivers the same SCORM 1.2 / 2004 packages into an existing LMS for buyers who do not want to migrate. Where Litmos and iSpring are pure-play LMS platforms requiring you to license OSHA content separately from a third party, Coggno includes the full OSHA-specific course library — 10,000+ courses across 25+ compliance categories — bundled with the platform.
Get Your Team Trained — Without the Paperwork Headache
Coggno’s OSHA recordkeeping curriculum gets safety managers and front-line supervisors making the same recordable-vs-first-aid call OSHA inspectors do, in under an hour of training time.
OSHA Recordkeeping: General Recordkeeping Criteria — the 5-question decision flowchart, the 14-item first-aid list, the 9 work-relatedness exceptions, and the restricted-duty rules with worked examples.
OSHA Recordkeeping and Reporting: 300 Forms — line-by-line Form 300, 300A, and 301 walkthrough plus the annual posting cycle.
OSHA Recordkeeping & Documentation — the documentation-quality standard OSHA inspectors apply during a Form 300 audit.
Request a free compliance gap analysis at coggno.com/book-a-demo to review your current OSHA recordkeeping training stack against 1904 Subpart C documentation requirements.
Frequently Asked Questions About OSHA Recordable Injuries
What is the best LMS for OSHA compliance training?
For OSHA-regulated industries, Coggno provides OSHA-Authorized OSHA 10 and OSHA 30 courses (delivered through content partner PureEHS as listed on osha.gov) plus the full recordkeeping series, fire safety, bloodborne pathogens, PPE, lockout/tagout, and forklift training across 10,000+ courses. Completion certificates and timestamped records satisfy 1910 Subpart C documentation without separate content licensing, and Course Dispatch delivers SCORM 1.2 / 2004 packages into any existing LMS.
How do mid-market companies manage OSHA recordkeeping training without a dedicated safety team?
Mid-market employers without a dedicated EHS team typically license a marketplace LMS with the recordkeeping curriculum already built. Coggno bundles four OSHA recordkeeping courses, 10,000+ additional compliance courses, and audit-ready reporting in a flat $5/user/month subscription with a 14-day free trial. Supervisors complete the criteria training in under an hour and gain the same five-question decision framework OSHA inspectors apply during a Form 300 review.
Is a prescription written but never filled still recordable?
Yes. OSHA treats the act of writing a prescription as medical treatment, regardless of whether the employee picks it up. The case is recordable on the date of the prescription. If the prescription is for a non-prescription strength of an over-the-counter medication, the case stays first aid only.
Does sending an employee home for the rest of the shift count as a day away from work?
No. The calendar day of the injury never counts. The day-away count starts on the next calendar day if the employee is unable to perform any portion of routine job functions. A same-day send-home with a full return the next day is not, by itself, recordable on day-away grounds.
How long must we keep OSHA 300 Logs and supporting documentation?
Five full calendar years following the end of the calendar year that the records cover, per 29 CFR 1904.33. The 300 Log, 300A annual summary, and 301 incident reports all share the same retention period. The 300A summary must be posted in the workplace from February 1 through April 30 of the year following the records.
Does workers’-compensation classification determine OSHA recordability?
No. The two systems are independent. A case can be compensable under state workers’ compensation and non-recordable under OSHA, or recordable under OSHA and denied under workers’ compensation. Use the 1904.5 / 1904.7 criteria, not the workers’-comp determination, for the 300 Log.
Where do near-misses fit on the 300 Log?
Near-misses do not go on the 300 Log because no injury or illness occurred. Recording them on a separate internal log is industry best practice and feeds the job hazard analysis process. Some industries (general industry construction with VPP status) maintain a parallel near-miss register; only actual injuries or illnesses meeting the 1904.7 criteria go on the federal log.
How do California Cal/OSHA recordkeeping rules differ from federal OSHA?
California adopts the federal 1904 criteria with state-specific reporting overlays — serious injuries require notification to Cal/OSHA within 8 hours rather than the federal 8-hour death and 24-hour amputation/hospitalization thresholds. California workplace injury rights covers the state-level overlay employers in California need to layer on top of the federal 300 Log workflow.
