Subpart A
The purpose of Part 1904 is to require employers to record and report work-related fatalities, injuries, and illnesses. See the Purpose in 1904.0 and the general Part 1904 requirements.
No — recording or reporting an injury, illness, or fatality does not mean the employer or employee was at fault or that an OSHA rule was violated. The note to 1904.0 explicitly states that recording/reporting does not imply fault, violation, or entitlement to benefits such as workers’ compensation. See 1904.0.
No — recording or reporting an injury or illness under Part 1904 does not mean the employee is eligible for workers’ compensation or other benefits. The note to 1904.0 makes clear that recordkeeping is separate from determinations about compensation or benefits.
Employers are responsible for recording and reporting work-related fatalities, injuries, and illnesses under Part 1904. The purpose paragraph of 1904.0 and the general rule at 1904 establish employer recordkeeping and reporting duties.
Yes — employers may use software-generated forms if those forms are equivalent to the OSHA Forms 300, 300A, and 301 as described in the recordkeeping rules. OSHA’s Software-generated OSHA recordkeeping forms letter explains that documents generated by software can substitute for OSHA forms so long as they meet the equivalency requirements in the regulation (for example, 1904.29). The forms must contain the same information, be as readable and understandable, be completed using the same instructions, and be producible for access and inspection when required.
Establishments meeting the rule’s size and industry criteria must submit certain OSHA Form 300A (and, for larger/higher-hazard establishments, Forms 300 and 301) data electronically, and OSHA enforces submission deadlines. The April 16, 2024 enforcement memorandum (Electronic injury record submission enforcement) summarizes that establishments with 250+ employees must submit Form 300A data, 20–249 employees in certain industries must submit Form 300A, and some 100+ establishments in specified industries must also submit Forms 300 and 301; employers must electronically submit the previous calendar year’s data by March 2, and OSHA may issue a citation for failure to submit up to six months after that date (see the memorandum and 1904).
OSHA is not enforcing the COVID-19 Healthcare ETS recordkeeping and reporting requirements adopted in 1910.502 at this time, but OSHA continues to enforce Part 1904 recordkeeping requirements generally. The February 5, 2025 memorandum (COVID-19 recordkeeping enforcement stay) states OSHA will not cite employers for violating certain COVID-19 log and reporting provisions in 1910.502 while noting that Part 1904 recordkeeping rules remain in effect and enforced.
No — using heated paraffin wax alone to treat a work-related injury is considered first aid, not medical treatment beyond first aid, and therefore is not recordable by itself. OSHA’s October 22, 2024 letter (Paraffin wax as medical treatment) explains that paraffin wax falls under the regulation’s definition of hot/cold therapy listed as first aid in 1904.7(b)(5)(ii)(E).
Yes — if paraffin wax is used together with other treatments that meet the general recording criteria (for example, prescription medication, physical therapy, restricted work, or days away), the case can become recordable. The October 22, 2024 letter (Paraffin wax as medical treatment) explains that while paraffin alone is first aid, its use in combination with other medical treatment beyond first aid or other recording criteria will make the case recordable under 1904 and 1904.7.
A travel-related fatality is work-related if the employee was engaged in activities in the interest of the employer at the time of the fatality, with certain exceptions. The June 12, 2024 letter (Work-related motor vehicle fatality) explains that 1904.5(a) presumes work-relatedness for events in the work environment but provides exceptions (for example, when an employee has established a “home away from home” at a hotel so that commuting between that temporary residence and the job may not be recordable). Use the travel-status rules in 1904.5(b)(6) to evaluate each situation.
Yes — employers may use NHANES-derived age-correction tables instead of OSHA’s Appendix F in certain circumstances, but they must follow conditions set by OSHA. The February 9, 2024 letter (NHANES age-correction table use) states OSHA will allow NHANES-based tables if all values come from a single dataset (no hybrids), a qualified clinician decides to age-correct and which table to use, and the table is applied consistently and retained with audiometric records; see also the general recordkeeping rules in 1904.
Generally no — employers are not required to record cases of the common cold or flu under the specific exception in [1904.5(b)(2)(viii)], but they must investigate and make a good-faith determination rather than simply assume the exception applies. The November 15, 2023 letter (Work-related illness recordkeeping exceptions) explains that while the regulation excludes the common cold and flu from recording, employers should evaluate each case using the recordkeeping rules in 1904 and not rely on blanket assumptions — contagious diseases outside that exception (e.g., tuberculosis, hepatitis A) may be recordable if work-related.
If the only treatment is first aid, ART, or exercise/stretching and the case meets no other recording criteria (like restricted work, days away, or medical treatment beyond first aid), the injury generally is not recordable; however, any independent recording criterion (e.g., a work restriction) makes it recordable. The May 2, 2024 enforcement guidance (Recordability of musculoskeletal injuries) explains that first aid treatments (including hot/cold therapy) are not recordable by themselves under [1904.7], but each recording criterion operates independently, so a first-aid-only treatment that nonetheless results in a restriction or medical treatment beyond first aid would be recordable under 1904.
An injury from workplace violence is work-related if it was caused by an event or exposure in the work environment, because work need only be a causal factor and the regulation applies a geographic presumption for events occurring at work. The May 17, 2023 letter (Work-relatedness of violent injury) explains that 1904.5(a) presumes injuries at work are work-related unless a specific exception applies; unforeseeable third-party criminal acts that occur in the work environment are generally still considered work-related unless a listed exception in 1904.5(b)(2) clearly applies.