A 2:40 p.m. call from the dock: is this an OSHA recordable injury?
At 2:40 p.m. on a Tuesday, a shift supervisor at a distribution center calls the safety manager. A forklift operator caught a hand between a pallet and a rack, drove himself to an urgent care clinic, and came back with a wrapped hand and a clinic note. The note mentions no restrictions. The supervisor wants to know whether to write it up.
The safety manager has a 300 log open, a half-remembered list of first-aid treatments and three other sites waiting on answers. Nothing in that call settles the question yet. The clinic's name does not settle it, and neither does the supervisor's instinct.
Three tests, applied in order, do the work, and each has a section number you can open. Some of them turn on facts you must gather first.
By the end of this article you will be able to walk any injury through those three tests, name the section behind each answer, and see where the regulation stops and your own decision begins.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
How an OSHA recordable injury is decided: three tests in sequence
The basic requirement sits in 29 CFR 1904.4(a) (29 CFR 1904.4 on eCFR, current October 15, 2026). In plain words, you record a fatality, injury or illness when it is work-related, it is a new case, and it meets at least one of the general recording criteria. All three conditions must hold. Failing any one of them ends the analysis for that case.
That gives you a sequence that works like a flowchart, even without the drawing:
| Step | Question | Section |
|---|---|---|
| 1 | Was the injury or illness work-related? | 1904.5 |
| 2 | Is it a new case, or a continuation of one already recorded? | 1904.6 |
| 3 | Does it meet a general recording criterion? | 1904.7 |
Order matters because it saves work. A condition that is not work-related never reaches the treatment question. A recurrence of something already on the log does not need a second entry. Teams that start with "what did the clinic do?" often spend time on cases that fail the first or second test.
Timing comes after the three tests. Once you decide a case is recordable, you must enter it on the OSHA 300 Log and complete the 301 Incident Report within seven calendar days of receiving information that a recordable injury or illness has occurred (29 CFR 1904.29(b)(3), current October 15, 2026). The clock runs from information that a recordable case occurred, and you decide whether a case is recordable. Reporting a severe injury to OSHA is a separate duty with its own clock, covered below.
Tests one and two: work-relatedness and new cases
Work-relatedness under 1904.5
Section 1904.5 asks whether an event or exposure in the work environment caused or contributed to the condition, or significantly aggravated a preexisting one (29 CFR 1904.5(a), current October 15, 2026). The regulation presumes work-relatedness for events or exposures in the work environment, unless an exception applies. Under 1904.5(b)(1), the work environment is "the establishment and other locations where one or more employees are working or are present as a condition of their employment."
The same section lists exceptions in 1904.5(b)(2). Examples in plain words include:
- voluntary participation in a wellness or fitness program;
- eating, drinking or preparing food for personal consumption;
- personal tasks done outside assigned working hours;
- the common cold or flu.
Read the full exceptions list in the regulation before relying on any summary, including this one.
The rule gives you the framework. You make the determination on the facts of each case. For the forklift operator, the questions are concrete. Where was he when it happened? What was he doing? Was the hand injury connected to a work activity or to something else? If the facts are unclear, document what you asked and what you learned. A work relatedness determination under 1904.5 is only as defensible as the notes behind it.
Preexisting conditions need particular care. A condition that work significantly aggravates can be work-related even though work did not start it. The regulation sets the standard for that judgment. You apply it.
New case versus recurrence under 1904.6
Section 1904.6 separates new cases from continuations (29 CFR 1904.6(a), current October 15, 2026). In plain terms, a case is new if the employee has not previously had a recorded injury or illness of the same type affecting the same body part. A case is also new if the employee did have one but had fully recovered, and a new workplace event or exposure brought the symptoms back.
The practical question for osha new case vs recurrence is whether the earlier case is still open. If an employee's wrist condition was recorded last quarter and has not resolved, a flare-up is generally the same case. If the symptoms had completely gone and a new event triggered them, it is generally a new case. The regulation has its own wording for illnesses, where signs and symptoms are the test.
Two consequences follow. First, a case that began in one year and causes days away in the next is recorded once, in the year it occurred. OSHA puts it directly in its 1904.7 text:
"No, you only record the injury or illness once" — 29 CFR 1904.7(b)(3)(ix), current October 15, 2026
Second, you update that single entry as days accumulate rather than opening a new line. Whether a case is new or a continuation is your decision, made on the employee's actual history. That means the log and the supporting facts need to agree.
Test three: the general recording criteria in 1904.7
If a case is work-related and new, Section 1904.7 asks whether it meets any general recording criterion (29 CFR 1904.7(a) and (b)(1), current October 15, 2026). In plain words, the criteria are:
- 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.
Meeting any one is enough. The first three are about outcome. The fourth is about what was done for the employee. The last two are catch-alls for cases that might not produce lost time or treatment.
Medical treatment beyond first aid
This is the criterion that drives most daily questions. Section 1904.7 draws a line between medical treatment and first aid, and it defines first aid by a list of specific treatments in 1904.7(b)(5)(ii), which 1904.7(b)(5)(iii) calls "a complete list" (29 CFR 1904.7, current October 15, 2026). In plain words, a treatment on that list is first aid. Treatment that goes beyond the list is medical treatment, and the case meets the criterion.
The line is also about substance, not setting. Under 1904.7(b)(5)(i), medical treatment does not include visits to a health care professional "solely for observation or counseling" or diagnostic procedures such as x-rays and blood tests. Under item (A) of the first-aid list, a non-prescription medication at nonprescription strength is first aid, while a recommendation to use it at prescription strength is medical treatment. Check each of these points against the current text, because the details matter.
Our separate guide to OSHA recordable versus first aid works through the list item by item.
Does an urgent care visit make an injury OSHA recordable?
No rule says that a particular type of facility makes a case recordable. The question is what care the employee received and whether it falls beyond first aid. An urgent care visit that ends with observation, an x-ray and a non-prescription pain reliever may stay on the first-aid side of the line. A visit that ends with sutures or prescription medication may not.
So for the forklift operator, the question to ask is what the clinic actually did. Get the clinic's discharge paperwork if the employee will share it, and ask what treatment was given. Then compare that treatment to the regulation's text. If you are unsure about a specific item, check the current text of 1904.7(b)(5) rather than relying on memory or a summary. The answer comes from the treatment, and you decide.
Restricted work and days away
When an injury leads to restricted duty or time off, the criteria shift to counting. Section 1904.7 sets out how to treat days away from work and days of restricted work or job transfer. Our guides on light duty and recordability and on counting days away from work cover the mechanics.
Three points are worth stating here. You may cap the total days away at 180 calendar days on the OSHA 300 Log (29 CFR 1904.7(b)(3)(vii)). You "begin counting days away on the day after the injury occurred or the illness began" (1904.7(b)(3)(i)). And you count calendar days the employee was unable to work, "regardless of whether or not the employee was scheduled to work on those day(s)" (1904.7(b)(3)(iv)). Read the rest of (b)(3) before you count, since small counting errors change what goes on the log.
Where the rule ends and your decision begins
The regulation tells you which questions to ask. It does not answer them for your employee. The pattern repeats at every step, and it is worth stating plainly.
Work-relatedness. The rule says what counts as the work environment and lists exceptions. You decide whether this event, on these facts, was work-related.
New case. The rule says when a case is new and when it continues. You decide, from the employee's history, which applies.
Medical treatment. The rule lists what counts as first aid. You decide whether the care given falls on that list.
Restricted work. The rule describes restriction and transfer. You decide whether the employee's actual duties were restricted.
Compensability. None of the three tests asks whether the claim is compensable. A workers' compensation outcome and an OSHA recording decision follow different rules and can differ for the same injury. Our guide to workers' comp claims versus OSHA recordables covers the difference. The employer, the carrier and the state each have their own role in that decision.
When health care professionals are involved, their recommendations matter, but the recording decision still belongs to the employer. A clinician's note can be the best evidence you have of what treatment was given or what restrictions were recommended. It does not decide recordability for you. If you disagree with a note or find it unclear, ask the clinic for clarification and keep a record of the question and the answer.
Write down the reasoning at the time you decide. A short entry covering the facts you had, the sections you applied and the conclusion you reached is enough. If OSHA or an insurer asks about the case later, that entry shows what you knew and when. It also helps when a new employee or a backup takes over the log.
Edge cases: timing, sites and temporary workers
Information that arrives late. The seven-calendar-day entry clock described above runs from information that a recordable case occurred. A clinic note that arrives on day nine can be the moment you learn the case is recordable. The date you received it matters, so record it. If later facts change your earlier decision, correct the log and note why.
One log per establishment. You must keep a separate OSHA 300 Log for each establishment expected to operate for one year or longer (29 CFR 1904.30(a)). A multi-site employer therefore makes recordability decisions site by site, even when one person owns the process. Consistency across sites depends on everyone applying the same sections the same way.
Temporary, leased and contract workers. Employers must record the recordable injuries and illnesses of workers they supervise day to day, including temporary, leased or contract workers who are not on their payroll (OSHA interpretation, 2018). The host employer and the staffing agency need to agree on who records what, using that supervision test. Detail on allocation beyond the supervision test is something to confirm with OSHA.
Recordable is not the same as reportable. A recordable case goes on your log. A severe injury goes to OSHA on its own clock, whether or not you have decided anything about recording. Under 29 CFR 1904.39(a), an in-patient hospitalization, amputation or eye loss must be reported to OSHA within 24 hours after it occurs, and a fatality within 8 hours after the death (OSHA, checked 2026). You report by telephone or in person to the nearest OSHA Area Office, by calling 1-800-321-6742, or through OSHA's online reporting application. California, Michigan and North Carolina run State Plans with their own notice rules, so check yours.
Small employers. A company with 10 or fewer employees at all times during the last calendar year is partially exempt from routine recordkeeping under 29 CFR 1904.1. It must still report fatalities and severe injuries under 1904.39 (29 CFR 1904.1(a)(1), current October 15, 2026). Whether an establishment's industry is also partially exempt is a separate question under 1904.2 that you should confirm in the regulation.
Where tools fit, and what to do next
Most employers who handle this today use email, calendar reminders and a spreadsheet. That works because it is flexible and familiar. The weakness is that a spreadsheet holds dates and decisions but not the rule that produced them, so the reasoning behind a past call is hard to reconstruct.
ClaimsIntake is reference and workflow software. It does not decide recordability, and it files nothing. The OSHA Recordability Decision Workbook is an Excel tool that walks a case through the three tests and computes the recordability logic, days-away and restricted counts, and a log that rolls into the 300A. The app is being built to add cited recordability prompts and a 300 log built only from cases you have decided. You decide recordability, and you file.
For a practical next step, take your last five injury cases and run each through the three tests in order. For each one, write down the facts you had, the section you relied on and your conclusion. Where you hesitate, check the current text of 1904.5, 1904.6 or 1904.7 on eCFR, or confirm with OSHA or your State Plan agency. If you do this for a handful of cases, you will quickly see which questions your team answers by habit and which need a written standard. Then check your log against the entry timing and make sure the 300 log reflects the decisions you made.
Reference material with citations, not legal advice. You decide recordability and compensability, and you file.
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