Blog Post

Understanding OSHA Recordkeeping: When to Record a Workplace Injury

Help your clients determine which injuries must be reported to OSHA with these guidelines.

Workplace safety is paramount in any industry, and employers are required to follow specific guidelines for recording and reporting workplace injuries and illnesses. The Occupational Safety and Health Administration (OSHA) mandates that certain work-related injuries and illnesses be recorded on OSHA logs to ensure accountability and safety improvement across all businesses.

However, not every workplace injury needs to be logged. In this article, we’ll break down the OSHA rules for when a workplace injury must be recorded, what exceptions exist, and how employers can ensure they are compliant.

Agents, help your clients and prospects master OSHA recordkeeping and ensure compliance with these two resources:

- The ABCs of OSHA Recordkeeping

- OSHA Recordable Cheat Sheet

OSHA Recordkeeping Basics

OSHA's recordkeeping requirements are designed to track workplace injuries and illnesses to help employers, workers, and OSHA identify hazards and risks, prevent future incidents, and improve safety measures. The main tool for this is the OSHA 300 log, where work-related injuries and illnesses that meet certain criteria must be documented.

Employers with more than 10 employees, unless they fall into a specific exemption category (such as certain low-risk industries like retail or finance), are required to maintain OSHA logs. Small employers with 10 or fewer employees are generally exempt, as are companies in industries that OSHA has classified as low-hazard.

What Constitutes a Recordable Injury or Illness?

According to OSHA, an injury or illness is recordable if it is work-related, a new case (not a recurrence of an existing condition), and meets one or more of OSHA’s general recording criteria. Below are the key factors that determine whether an injury needs to be recorded:

Work-Related Injuries or Illnesses

OSHA requires that injuries or illnesses be recorded if they occur in the work environment and are caused, contributed to, or significantly aggravated by events or exposures in the workplace. The “work environment” includes the establishment and other locations where employees are working or present as a condition of their employment.

Non-work-related injuries, such as those occurring during an employee’s commute or while participating in voluntary offsite activities, are generally not recordable. However, even when an injury occurs offsite, if the employee is conducting work-related tasks, the injury may need to be recorded.

General Recording Criteria

Once an injury or illness is determined to be work-related, it must be recorded if it meets OSHA's general criteria, including:

- Death: Any work-related fatality must be recorded and reported to OSHA within 8 hours.

- Loss of Consciousness: If an employee loses consciousness due to a workplace injury or illness, it must be recorded.

- Days Away from Work: Any work-related injury or illness that results in one or more days away from work is recordable.

- Restricted Work or Job Transfer: If the employee cannot perform their regular duties and must be assigned restricted work or transferred to another job due to the injury, it must be recorded.

- Medical Treatment Beyond First Aid: If the injury requires more than first aid, such as stitches, prescription medication, or physical therapy, it must be recorded.

Specific Injuries and Illnesses

In addition to the general criteria, certain injuries and illnesses must be recorded, including:

- Fractures and Amputations: Any broken bone or amputation must be recorded.

- Punctured Eardrums: Any work-related incident that results in a punctured eardrum.

- Chronic and Acute Illnesses: Work-related chronic illnesses, such as hearing loss due to long-term exposure to noise or respiratory conditions from exposure to chemicals, must be recorded.

Additionally, there are specific requirements for conditions like tuberculosis, bloodborne pathogens, and needle sticks. For instance, if an employee is exposed to bloodborne pathogens at work, and it leads to illness, that must be recorded.

What Injuries Are NOT Recordable?

Not every incident needs to be documented on the OSHA 300 log. OSHA allows for certain exceptions where an injury or illness is not considered recordable, even if it is work-related. These exceptions include:

- First Aid Only: If the treatment provided for the injury is classified as first aid, such as using a non-prescription medication at non-prescription strength, cleaning a wound, or applying a bandage, the injury is not recordable.

- Diagnostic Procedures: Visits to a doctor for purely diagnostic purposes, like X-rays or blood tests, do not require recording unless the diagnosis reveals an injury or illness that meets recordable criteria.

- Personal Tasks: If the employee is injured while engaged in a personal task during work hours, such as eating or grooming, it is not typically recordable.

- Motor Vehicle Accidents in the Parking Lot: If an employee is injured in a car accident while in a parking lot or company-controlled access road while commuting, the injury is not recordable, provided they are not conducting work-related tasks.

First Aid vs. Medical Treatment

One of the most important distinctions in OSHA recordkeeping is between first aid and medical treatment. This distinction determines whether a workplace injury needs to be recorded. Injuries that only require first aid are not recordable, while those requiring medical treatment beyond first aid must be documented.

What is Considered First Aid?

OSHA defines first aid as any one-time treatment and follow-up for minor injuries that typically do not require the expertise of a medical professional. The key characteristic of first aid is that it involves simple treatments aimed at preventing the injury from worsening, rather than curing a serious health issue.

Here are some common examples of first aid that do not need to be recorded:

- Non-prescription medications (at non-prescription strength): Providing over-the-counter medications like ibuprofen, aspirin, or topical creams does not qualify as medical treatment if used at normal doses.

- Cleaning a wound: Washing or cleaning the surface of a wound or cut without using stitches or more invasive procedures.

- Bandages, gauze, and butterfly strips: Applying simple wound coverings like adhesive bandages or butterfly strips to close a small cut is considered first aid. However, using stitches or staples would elevate the treatment to medical care.

- Hot or cold therapy: Applying ice packs, heat pads, or soaking in warm water to relieve discomfort or swelling.

- Non-rigid supports: Using items like elastic bandages, wraps, or non-rigid back supports to stabilize an injured area temporarily.

- Drilling a fingernail or toenail to relieve pressure or draining a blister without infection: These minor procedures relieve discomfort but don’t involve more invasive treatments.

- Eye patches for minor eye irritation.

These first aid treatments can be administered at the worksite or elsewhere without triggering the need for OSHA recording.

What is Considered Medical Treatment?

In contrast, medical treatment involves care beyond first aid that requires the intervention of a medical professional. If an injury or illness requires any of the following, it would be considered medical treatment, making the case recordable:

- Prescription medications: Any medication prescribed by a doctor, even over-the-counter drugs at prescription strength.

- Stitches, sutures, or staples: Closing wounds with these methods is considered medical treatment.

- Physical therapy or chiropractic treatment: These types of ongoing treatments for injuries are considered medical care.

- Casting or splinting a broken bone: Even a minor fracture requires medical treatment, so this would need to be recorded.

- Surgical procedures: Any procedure that requires surgery, whether minor or major, must be recorded.

Why the Distinction Matters

The difference between first aid and medical treatment has significant implications for employers. Properly classifying treatments ensures compliance with OSHA’s recordkeeping requirements and avoids over-reporting or underreporting incidents. Over-reporting can lead to inflated injury rates, while underreporting can result in penalties or increased scrutiny during OSHA inspections.

The Importance of OSHA Recordkeeping

Accurate recordkeeping is essential for multiple reasons. For employers, maintaining OSHA logs allows them to monitor their safety performance and address any dangerous trends or recurring hazards. It also provides documentation that can protect them in case of legal action related to workplace injuries.

For employees, OSHA logs offer transparency into workplace risks and the company’s safety track record. These records also ensure that workplace accidents are being addressed properly.

OSHA also uses injury and illness data to target high-risk industries and workplaces for enforcement actions, inspections, and the development of new safety standards.

Reporting vs. Recording

It's important to distinguish between recording an injury or illness on the OSHA 300 log and reporting it to OSHA. As previously mentioned, certain severe incidents—such as fatalities, hospitalizations, amputations, or loss of an eye—must be reported to OSHA within a specific timeframe (8 to 24 hours, depending on the incident). However, other recordable injuries and illnesses do not need to be directly reported but must be documented in your logs.

OSHA Electronic Submission Requirement

Employers are also required to electronically submit OSHA injury and illness data annually. Companies with more than 250 employees, or those with 20–249 employees in high-risk industries, must electronically submit the information from their OSHA 300A form (the summary of all recorded incidents) by March 2 each year.

Conclusion

Understanding OSHA's recordkeeping requirements can seem complex, but following the guidelines is essential for compliance and workplace safety improvement. As an agent, supporting your clients (and prospects) through this requirement adds significant value to your relationship and helps them avoid fines and penalties.

Send the following free resources to your clients and prospects today: