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OSHA 1904.7

General recording criteria

Subpart C

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1904.7(a), what are the general recording criteria that make an injury or illness recordable?

An injury or illness 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 if it is a significant diagnosed condition by a physician or other licensed health care professional. See 1904.7(a) and the general discussion in 1904.7.

Under 1904.7(b)(2), how must I record a work-related death on the OSHA 300 Log and what reporting requirement applies?

You must mark the death box on the OSHA 300 Log and report the fatality to OSHA within eight hours. Record the case on the OSHA 300 Log by placing a check for death and provide the required immediate report to OSHA as described in 1904.7(b)(2) and 1904.39.

Under 1904.7(b)(3)(i), when I count days away from work for recordkeeping, do I count the day the injury occurred?

No, you start counting days away beginning the day after the injury occurred or the illness began. See 1904.7(b)(3)(i).

Under 1904.7(b)(3)(ii)-(iii), how do I record recommended days away or return-to-work recommendations from a physician when the employee does not follow them?

You record the recommended number of days away or the physician's recommended return date even if the employee does not follow the recommendation. If two or more health professionals give different recommendations, you may choose the most authoritative recommendation to use for the log. See 1904.7(b)(3)(ii) and 1904.7(b)(3)(iii).

Under 1904.7(b)(3)(iv)-(vii), do I include weekends and holidays in the days-away or restricted-work totals, and is there a maximum number of days I must track?

Yes, you count calendar days (including weekends, holidays, vacations, and other days off) if the employee was unable to work on those days because of the injury or illness, and you may cap the total at 180 calendar days. See 1904.7(b)(3)(iv) and 1904.7(b)(3)(vii).

Under 1904.7(b)(3)(viii)-(ix), what do I do about counting days if the employee leaves the company or the days fall in the next calendar year?

If the employee leaves for reasons unrelated to the illness or injury, you may stop counting days away or of restriction; if the employee leaves because of the injury or illness, you must estimate and enter a total day count on the OSHA 300 Log. Also, record the case in the year the injury or illness occurred even if days away extend into the next calendar year. See 1904.7(b)(3)(viii) and 1904.7(b)(3)(ix).

Under 1904.7(b)(4)(i)-(ii), how is "restricted work" defined for recordkeeping purposes?

Restricted work occurs when the injury or illness prevents the employee from performing one or more routine job functions they perform at least once per week, or when a physician or other licensed health care professional recommends they not perform one or more routine functions or not work their full scheduled workday. See 1904.7(b)(4)(i) and 1904.7(b)(4)(ii).

Under 1904.7(b)(4)(v), how do I treat a partial work shift when the worker can only work part of a day because of the injury?

A partial work shift (other than the day the injury occurred) counts as at least one day of restricted work or job transfer and must be recorded as a restricted work day. See 1904.7(b)(4)(v).

Under 1904.7(b)(4)(vi)-(viii), if a physician gives a vague restriction like "light duty," how should I determine whether the case is recordable as restricted work?

If the restriction is unclear, you should ask the physician whether the employee can perform all routine job functions and work their full assigned shift; if the answer to either question is "No," the case is restricted and recordable. If you cannot obtain clarification, record the case as restricted work. See 1904.7(b)(4)(vii) and 1904.7(b)(4)(viii).

Under 1904.7(b)(4)(ix)-(xi), when is a transfer to another job recordable and how do I count those days?

If you assign an employee to a job other than their regular job for part of a day (not including the day of injury), that is a job transfer and must be recorded in the same box as restricted work; count transfer days the same way you count days away or restricted work. If you permanently change the job so the routine functions no longer exist, you may stop counting after at least one recorded day. See 1904.7(b)(4)(ix), 1904.7(b)(4)(x), and 1904.7(b)(4)(xi).

Under 1904.7(b)(5) and (b)(5)(ii), what treatments are considered "first aid" and therefore not "medical treatment beyond first aid" for recordkeeping?

The treatments listed in 1904.7(b)(5)(ii)—such as using nonprescription medications at nonprescription strength, administering tetanus shots, cleaning or flushing surface wounds, using bandages or Steri-Strips™, hot or cold therapy, non-rigid supports, and a defined list of other simple treatments—are considered first aid and are not medical treatment for recordkeeping purposes. See 1904.7(b)(5) and 1904.7(b)(5)(ii).

How does OSHA treat paraffin wax heat therapy for recordkeeping—first aid or medical treatment? (See the paraffin wax Letter of Interpretation)

When heated paraffin wax is used alone to relieve pain or stiffness, OSHA considers it hot therapy and therefore first aid, so the case is not recordable on that basis alone. See the Letter of Interpretation on paraffin wax as medical treatment at https://www.osha.gov/laws-regs/standardinterpretations/2024-10-22 and 1904.7(b)(5)(ii)(E). Note that if paraffin wax is combined with other recordable medical treatment (e.g., prescription drugs, physical therapy) or the case meets another general criterion, the case becomes recordable.

Under 1904.7(b)(5)(iii)-(iv), is the list of first aid treatments exhaustive and does it matter who provides the first aid?

Yes, the list in 1904.7(b)(5)(ii) is a complete list of first aid treatments for Part 1904, and the professional status of the person providing the treatment does not change whether a treatment is considered first aid. See 1904.7(b)(5)(iii) and 1904.7(b)(5)(iv).

Under 1904.7(b)(5)(v), what if a health care professional recommends medical treatment but the employee refuses to follow it—must I still record the case?

Yes, you must record the case if a physician or other licensed health care professional recommends medical treatment, even if the employee does not follow the recommendation. See 1904.7(b)(5)(v).

Under 1904.7(b)(6), is any work-related loss of consciousness recordable regardless of duration?

Yes, any work-related loss of consciousness is recordable regardless of how long the employee remained unconscious. See 1904.7(b)(6).

Under 1904.7(b)(7), which diagnosed conditions are always recordable even if they don't meet other criteria?

Work-related cases involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum must always be recorded at the time of diagnosis by a physician or other licensed health care professional. See 1904.7(b)(7).

According to the April 29, 2025 Letter of Interpretation, can employer software-generated forms be used in place of OSHA Forms 300 and 300A?

Yes—if the software-generated documents meet the requirements for equivalent forms under Part 1904 (i.e., contain the same information, are as readable and understandable, and use the same instructions), they can be used as substitutes for OSHA Forms 300 and 300A. See the Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 and the general Part 1904 requirements in 1904.

Per the April 16, 2024 enforcement memo on electronic injury record submission, which establishments must submit Form 300A data electronically and by when?

Establishments with 250+ employees must submit Form 300A data electronically, and certain establishments with 20–249 employees in designated higher-hazard industries must also submit Form 300A; data for the prior calendar year are due by March 2 each year. See the enforcement memorandum at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16 and 1904.

How does OSHA treat work-related motor vehicle fatalities for traveling employees under the June 12, 2024 Letter of Interpretation?

OSHA presumes injuries and deaths that occur in the work environment are work-related, and travel-status cases are work-related when the employee is engaged in activities in the interest of the employer; exceptions apply if the employee has established a "home away from home" (e.g., checked into a hotel) or other specified exceptions. See the Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-12 and the general Part 1904 rules in 1904.

How should I treat musculoskeletal injuries that receive only first aid, Active Release Techniques (ART), or exercise/stretching per the May 2, 2024 memorandum?

If the only treatment for a work-related musculoskeletal injury is first aid, ART, or exercise/stretching and there are no work restrictions, days away, or medical treatment beyond first aid, the case generally is not recordable; however, if the case results in restricted work, days away, medical treatment beyond first aid, loss of consciousness, or is a significant diagnosed condition, it is recordable. See the enforcement guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-05-02 and 1904.7(b)(5)(ii).