Recording work-related injuries

Employers must record each work-related injury or illness that is a new case and that meets one or more of the recording criteria in Part 1904.4(a). In plain terms, that means you record a case only if (1) the event or exposure was work-related, (2) it is a new case (not a continuation of a prior recorded case), and (3) it results in one or more of the general recording outcomes such as death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed condition. See 1904.4(a) and the general rule at 1904.

Follow the decision steps in order: first decide work-relatedness, then whether it is a new case, and finally whether it meets any of the general or specific recording criteria. Practically, that means (a) determine if the event or exposure occurred in the work environment and caused or contributed to the condition (1904.5), (b) determine if it is a new case per 1904.6, and (c) determine whether it meets one or more of the general criteria in 1904.7 or the additional criteria in 1904.8–1904.12. OSHA provides this same stepwise approach in 1904.4(b)(2).

An injury or illness is work-related if an event or exposure in the work environment caused, contributed to, or significantly aggravated it; work-relatedness is presumed for events in the work environment unless a specific exception applies. The regulation defines the work environment and presumes work-relatedness, but it also lists exceptions (for example, personal tasks unrelated to work, purely social activities, or certain commuting situations) that can rebut that presumption; see 1904.5 and the cross-reference in 1904.4(b)(1)(i). For guidance on applying exceptions and making good-faith determinations, see OSHA's interpretation on the common cold/flu and other work-relatedness questions at https://www.osha.gov/laws-regs/standardinterpretations/2023-11-15.

A new case is one that represents a new injury or illness and not simply the continuation of a previously recorded condition; you record a case when it meets the regulatory definition of a new case in 1904.6. In practice, that means you check whether the worker is being treated for the same condition as a previously recorded case, whether the condition was previously recorded, and whether current treatment or diagnosis reflects a new case as described in 1904.6.

A case is recordable if it results in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or is a significant diagnosed condition; these are the general criteria in 1904.7. Remember each criterion operates independently (for example, if only first aid is given but the worker is restricted from normal duties, the case is still recordable). See 1904.7 and OSHA guidance on musculoskeletal cases when first aid or exercises are used at https://www.osha.gov/laws-regs/standardinterpretations/2024-05-02.

You must apply the additional, case-specific recording rules found in 1904.8 through 1904.12 when those types of cases are involved. These sections provide special criteria (for example, needlestick and sharps injuries or occupational hearing loss) that supplement the general criteria in 1904.7.

The use of heated paraffin wax alone to treat a work-related injury is considered first aid and not medical treatment for recordkeeping purposes. OSHA explicitly determined that paraffin wax used as a heat therapy to relieve pain, increase blood flow, or relax muscles falls within the "hot or cold therapy" first-aid listing in [1904.7(b)(5)(ii)(E)], so such treatment alone does not make the case recordable; see OSHA's letter of interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-22 and the general recording rules in 1904.7. Note: if paraffin wax is used together with medical treatment beyond first aid (e.g., prescription medications, physical therapy) or the case results in restricted work or days away, the case may become recordable.

Treatments listed as first aid in the rule (for example, using nonprescription medication at nonprescription strength, cleaning minor wounds, using hot or cold therapy, bandages, and non-rigid supports) are not considered medical treatment for recordkeeping; see the detailed list in 1904.7(b)(5)(ii). For musculoskeletal injuries, OSHA has clarified that if the only treatment is first aid, Active Release Techniques (ART), or exercises/stretching without medical treatment beyond first aid or work restrictions, those cases are generally not recordable—see OSHA's enforcement guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-05-02 and the general criteria in 1904.7.

An injury to an employee on travel status is work-related if the employee was performing activities in the interest of the employer, but an employee who has checked into a hotel or temporary residence is considered to have established a "home away from home," and injuries that occur while at that temporary residence are generally not work-related. OSHA explains these rules in 1904.5 and applied them to a motor-vehicle fatality scenario in its interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-12; the key is whether the employee was engaged in employer-related activities at the time of the injury or had effectively left the work environment by establishing a temporary home.

Yes — injuries from third-party criminal acts that occur in the work environment are generally presumed work-related unless a specific exception applies. OSHA's recordkeeping rule presumes work-relatedness for events that occur in the work environment and will record such injuries unless an exception in 1904.5(b)(2) applies; OSHA addressed a shooting following a vehicle accident and concluded the injury remained work-related in its interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2023-05-17.

Yes — employers may use software-generated or alternate paper forms if those forms are equivalent to the OSHA forms and meet the requirements in 29 CFR 1904.29 and related instructions. OSHA's April 29, 2025 letter confirmed that equivalent electronic or paper forms that contain the same information, are as readable and understandable, and are completed using the same instructions as OSHA Forms 300 and 300A may be used, and that electronic systems must be able to produce equivalent forms for access and inspection; see OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the general Part 1904 requirements at 1904.

Establishments meeting the size/industry thresholds specified in Part 1904 must electronically submit OSHA Form 300A data (and in some cases Form 300 and Form 301 data) by March 2 for the prior calendar year; failure to submit can lead to citations issued within a six-month window. OSHA's enforcement guidance summarizes who must submit: establishments with 250+ employees generally must submit Form 300A; certain 20–249 employee establishments in higher-hazard industries must also submit Form 300A; and certain larger establishments must submit Forms 300 and 301 as specified — see OSHA's enforcement update at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 and the general Part 1904 provisions at 1904. OSHA may issue a citation for failure to submit up to six months after the March 2 deadline, as explained in that guidance.

OSHA will identify non-responders using its Injury Tracking Application and may issue citations or perform full recordkeeping audits for employers who failed to submit required Form 300A (and in some cases Form 300/301) data; enforcement action can be taken within the six-month period following the March 2 submission deadline. The Directorate of Enforcement Programs' April 16, 2024 memorandum explains OSHA's updated enforcement procedures, how Area Offices will use ITA data to identify failures to submit, and that citations may be issued for missing submissions; see https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 and the broader rule at 1904.

Employers should not automatically apply the common cold/flu exception; they must make a reasonable, good-faith determination whether the illness is indeed the common cold or flu because the exception removes the recording requirement for those illnesses regardless of where they were contracted. OSHA's November 15, 2023 interpretation emphasizes that the employer must investigate symptoms and exposures and apply the same analysis used for other illnesses rather than simply assuming the exception applies; see https://www.osha.gov/laws-regs/standardinterpretations/2023-11-15 and the work-relatedness rule at 1904.5.

Musculoskeletal injuries are generally not recordable if the only treatments are first aid, ART, and/or exercises/stretching and there are no other recordable outcomes like restricted work or medical treatment beyond first aid. OSHA's May 2, 2024 memorandum clarifies that if ART, exercise, or first aid is the only treatment and the case does not produce days away, restricted work, transfer, medical treatment beyond first aid, loss of consciousness, or a significant diagnosed condition, the case is usually not recordable; see https://www.osha.gov/laws-regs/standardinterpretations/2024-05-02 and 1904.7. Remember each recording criterion is independent—if any other criterion applies, the case is recordable.

Employers should keep a clear, contemporaneous record of the facts relied upon to determine recordability—such as incident reports, medical findings, dates of treatment, and any analysis showing why a case did or did not meet the criteria in Part 1904—so the decision can be shown to be a reasonable, good-faith determination. OSHA's guidance on work-relatedness and the common cold/flu exception stresses that employers must investigate and base decisions on available evidence rather than assumptions; see https://www.osha.gov/laws-regs/standardinterpretations/2023-11-15 and the core rule in 1904.

Yes — employers must make OSHA Forms 300/300A/301 or equivalent records available to employees, former employees, their representatives, and authorized government representatives as required by Part 1904's access provisions. OSHA's software-generated forms interpretation explains that equivalent electronic forms must be producible for access and inspection under the regulation and that records must be available per the access rules referenced in that letter; see https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the overarching Part 1904 requirements at 1904.

Yes — employers may use NHANES-derived age-correction tables other than OSHA's Appendix F, but only if the tables are calculated consistently from a single NHANES dataset and a qualified audiologist or physician decides to use them and documents that decision; OSHA allows NHANES-based tables under those conditions. OSHA's February 9, 2024 interpretation explains acceptable use of NHANES data, requires consistent dataset calculations, and states that a certified audiologist or physician must select and apply the alternative tables equitably for audiometric records; see https://www.osha.gov/laws-regs/standardinterpretations/2024-02-09 and the broader Part 1904 guidance at 1904.

OSHA is not currently enforcing the COVID-19-specific record and reporting provisions of 29 CFR 1910.502, but employers must still follow the general Part 1904 recordkeeping requirements for work-related illnesses unless another enforcement action or guidance applies. OSHA's February 5, 2025 memorandum announced an enforcement stay for the COVID-19 ETS recordkeeping/reporting provisions and stated OSHA will continue to enforce Part 1904; see https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 and 1904.