OSHA Recordkeeping (29 CFR 1904)

29 CFR Part 1904 covers two related but distinct obligations: recording work-related injuries and illnesses on a running log, and reporting the most serious events directly to OSHA.

These are different tests with different triggers and different deadlines, and confusing them is one of the most common US compliance mistakes. This page explains both. It is not legal advice.

Recordable vs reportable — the distinction that matters

	Reportable (1904.39)	Recordable (1904.4 – 1904.7)
What you do	Contact OSHA directly	Enter the case on your 300 log
Triggered by	Fatality; in-patient hospitalisation; amputation; loss of an eye	Any case meeting the general recording criteria — a much wider net
Deadline	8 hours for a fatality, 24 hours for the others	7 calendar days
Applies to	All employers, including those exempt from recordkeeping	Employers subject to Part 1904

A sprained back that keeps someone on restricted duties for a week is recordable but not reportable. A worker hospitalised overnight is both. An employee sent home for the afternoon and treated with an ice pack is neither.

Are you exempt?

Two partial exemptions from routine recordkeeping (1904.1 and 1904.2):

Small employers — if you had 10 or fewer employees at all times during the previous calendar year
Low-hazard industries — a published list of exempt industry classifications (Appendix A to Subpart B), which includes many professional services, retail, insurance, and similar

Both exemptions are partial. If you are exempt you still must:

Report fatalities and severe injuries under 1904.39
Complete an OSHA injury survey if you are specifically asked to

If you are near the 10-employee line, count carefully — it is all employees across the whole company (including part-time, seasonal, and temporary workers you supervise), not per site, and it is at all times during the year, so a single day above 10 removes the exemption.

The recordability test

A case must be recorded if it is work-related, is a new case, and meets at least one of the general recording criteria.

An injury or illness is work-related if an event or exposure in the work environment either caused it or significantly aggravated a pre-existing condition. Work-relatedness is presumed for anything happening at work — but there is a list of exceptions, including:

The employee was present as a member of the general public
Symptoms surface at work but result solely from a non-work event
Voluntary participation in a wellness programme, or a recreational activity
Eating or drinking food for personal consumption
Personal grooming, self-medication for a non-work condition, or intentional self-inflicted injury
Common cold or flu
Mental illness — unless a licensed mental-health professional provides an opinion that it is work-related

Step 2 — Is it a new case? (1904.6)

It is a new case if the employee has not previously had a recorded case of the same injury or illness, or they had recovered completely from a previous one and a new workplace event caused it to reappear.

Step 3 — Does it meet the general recording criteria? (1904.7)

Record it if it involves any of:

Death
Days away from work
Restricted work or transfer to another job
Medical treatment beyond first aid
Loss of consciousness
A significant injury or illness diagnosed by a physician or other licensed health care professional (for example cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum — recordable even with no treatment or lost time)

“Beyond first aid” — the closed list

This is the criterion that catches people out. OSHA defines first aid as a closed list at 1904.7(b)(5)(ii). Anything on the list is first aid; anything not on it is medical treatment, and the case is recordable.

First aid is:

Using a non-prescription medication at non-prescription strength
Tetanus immunisations
Cleaning, flushing, or soaking wounds on the skin surface
Wound coverings — bandages, gauze pads, butterfly bandages, Steri-Strips
Hot or cold therapy
Non-rigid means of support — elastic bandages, wraps, non-rigid back belts
Temporary immobilisation devices used to transport an accident victim
Drilling a fingernail or toenail to relieve pressure, or draining a blister
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 swab, or other simple means
Finger guards
Massage
Drinking fluids for relief of heat stress

The consequence: prescription-strength medication makes a case recordable even if the identical drug at over-the-counter strength would not. Sutures, rigid splints, physical therapy, and chiropractic treatment are all medical treatment.

Note that diagnostic procedures are not treatment — an x-ray or blood test alone does not make a case recordable, and neither does an observation-only visit.

The three forms

Form	What it holds
OSHA 300 — Log of Work-Related Injuries and Illnesses	One line per recordable case: employee name, job title, date, where it occurred, a description, the case classification, day counts, and the injury/illness type
OSHA 301 — Injury and Illness Incident Report	The detailed per-case record: how the injury occurred, what object or substance harmed the employee, treating physician, facility, whether treated in an emergency room, whether hospitalised overnight
OSHA 300A — Summary of Work-Related Injuries and Illnesses	Annual totals by classification and illness type, plus average employee count and total hours worked

Records are kept per establishment — a single physical location (1904.30) — not per company, and must be retained for five years. The 300 log must be updated during that retention period if the facts of a case change; many cases become more serious after they are first recorded.

Day counts

Days away from work and days of restricted work or transfer are counted in calendar days, beginning the day after the incident, and capped at 180 days each.

Privacy-concern cases

For certain cases (1904.29(b)(7)) you must not enter the employee’s name on the 300 log. Write “Privacy Case” instead and keep a separate, confidential list linking the case number to the name:

Injury or illness to an intimate body part or the reproductive system
Injury or illness resulting from sexual assault
Mental illness
HIV infection, hepatitis, or tuberculosis
Needlestick and sharps injuries contaminated with another person’s blood
Other illnesses, where the employee voluntarily requests that their name not be entered

You must also withhold any descriptive information that could identify the employee when releasing the log.

The annual cycle

When	What
Throughout the year	Record each case within 7 calendar days
End of year	Review the log for completeness and accuracy; complete the 300A
Before 1 February	A company executive personally certifies the 300A (1904.32) — the owner, a corporate officer, the highest-ranking official at the establishment, or that person’s supervisor
1 Feb – 30 Apr	Post the 300A where notices to employees are customarily posted
By 2 March	Electronic submission to OSHA’s Injury Tracking Application, if it applies to you
For 5 years	Retain and update

Who must submit electronically (1904.41)

250+ employees at an establishment in an industry not exempt under 1904.2 → submit the 300A
20–249 employees at an establishment in a designated high-hazard industry (Appendix A) → submit the 300A
100+ employees at an establishment in an Appendix B industry → submit Forms 300, 301, and 300A

Reporting severe injuries (1904.39)

Separate from the log, and applying even to employers otherwise exempt from recordkeeping:

Event	Deadline
Fatality (occurring within 30 days of the work-related incident)	8 hours
In-patient hospitalisation of one or more employees	24 hours
Amputation	24 hours
Loss of an eye	24 hours

Report by calling the nearest OSHA area office, calling 1-800-321-OSHA (6742), or using the online reporting form. In-patient hospitalisation, amputation, and loss of an eye are reportable only if they occur within 24 hours of the work-related incident.

Some exclusions: fatalities from motor-vehicle accidents on public roads (unless in a construction work zone), and those occurring on commercial aircraft, trains, subways, or buses.

What SteadyOn supports today

Requirement	Status
Recording incidents with descriptions, dates, people, and investigation	✅ Incidents module
Flagging an incident as reportable and recording the category	✅ Notifiable status + OSHA reportable categories, seeded automatically for US organisations
Recording when you notified OSHA and any reference number	✅ Notify Regulator tab
Linking corrective actions to an incident	✅ Actions
Attaching photographs and evidence	✅ Attachments
Complete audit trail of every change	✅ The Log
The 300 log, 301 forms, and the 300A summary	❌ Not yet supported
The recordability determination and day counts	❌ Not yet supported
Annual certification, posting, and ITA submission	❌ Not yet supported

If you are subject to Part 1904, you will need to maintain the statutory forms separately for now. SteadyOn’s incident records give you the underlying facts — dates, descriptions, people, and treatment notes — but the forms themselves and the recordability determination are not produced by the product.

Support for the 300 log is on the roadmap. If it matters to you, tell us — it helps us prioritise.

Where to go next

US Regulatory Framework — how Part 1904 sits alongside the rest
State Plans and Cal/OSHA — states may have additional or earlier reporting requirements
US Privacy and Employee Records — confidentiality obligations around injury and medical data