Medical removal recording criteria

Yes — if an employee is medically removed under the medical surveillance requirements of an OSHA standard, you must record the case on the OSHA 300 Log. See 1904.9(a).

• This rule applies even if the removal results from surveillance or monitoring required by a specific OSHA standard (for example, lead or benzene standards).
• When you make the entry, follow the classification rules in 1904.9(b)(1).

You must enter each medical removal case on the OSHA 300 Log as either a case involving days away from work or a case involving restricted work activity, depending on how you decide to comply with the medical removal requirement. See 1904.9(b)(1).

• If the employer’s way of complying requires the worker to be away from work, list it as days away. If the worker is kept on restricted duty or given alternate work, list it as restricted work.
• If the removal is the result of a chemical exposure, also check the “poisoning” column as required by 1904.9(b)(1).

Check the "poisoning" column when the medical removal is the result of a chemical exposure. See 1904.9(b)(1).

• This applies when a specific chemical standard (for example lead, benzene, cadmium) requires medical removal because of exposure or medical test results.
• Even when you check the poisoning column, you still classify the case as days away or restricted work as described in 1904.9(b)(1).

No — not all OSHA standards include medical removal provisions. See 1904.9(b)(2).

• Some standards, such as the bloodborne pathogens and noise standards, do not have medical removal provisions.
• Many chemical-specific standards do include medical removal (for example lead, cadmium, methylene chloride, formaldehyde, and benzene), so check the substance-specific standard when exposure is involved.

No — if the removal was voluntary and occurred before the medical removal levels in an OSHA standard were met, you do not have to record the case on the OSHA 300 Log. See 1904.9(b)(3).

• This applies to employer-initiated, voluntary removals done as a precaution before the regulatory medical removal criteria are triggered.
• If later the employee meets the medical removal criteria under an OSHA standard, then the later qualifying event must be recorded per 1904.9(a).

Yes — a medical removal required by an OSHA standard must be recorded on the OSHA 300 Log even if the only medical treatment provided otherwise would qualify as first aid. See 1904.9(a).

• For example, OSHA has clarified that some heat therapies (like paraffin wax) are first aid and by themselves would not make a case recordable, but that does not change the requirement to record when the removal itself is required by an OSHA standard. See the paraffin wax letter of interpretation for how thermal treatments are treated as first aid in general.
• So if removal is mandated by a substance-specific standard, record the medical removal per 1904.9(a), regardless of first-aid-only treatment.

You must record the medical removal on the OSHA 300 Log and classify it as days away or restricted work as described in 1904.9(b)(1); if the removal is the result of chemical exposure such as lead or benzene, you must also check the "poisoning" column. See 1904.9(b)(1) and note that specific chemical standards (including lead and benzene) are listed in 1904.9(b)(2).

• Record the case even if the employer provides pay or alternative duties; the classification depends on how you comply with the standard (days away vs restricted work).
• Keep supporting documentation (medical records, exposure data, and the standard that required removal) with your recordkeeping files.

Record the case as restricted work activity (not days away) if your method of complying with the medical removal requirement keeps the worker on the payroll doing restricted or alternate duties. See 1904.9(b)(1).

• The regulation lets the employer choose whether compliance with the medical removal requirement results in days away or restricted work; record according to that choice.
• If the reassignment is due to a chemical exposure removal, also check the "poisoning" column per 1904.9(b)(1).

Yes — if at any later point the employee meets the medical removal criteria in an OSHA standard, that qualifying medical removal must be recorded on the OSHA 300 Log under 1904.9(a).

• The initial voluntary removal before regulatory thresholds are met is not recordable under 1904.9(b)(3).
• Keep good documentation showing dates and measurements so you can demonstrate when the regulatory criteria were actually met and when the recordable event occurred.

Yes — you may use electronic or software-generated forms as substitutes for OSHA Forms as long as they are equivalent to the OSHA forms and meet the requirements for equivalent forms. See 1904 and the OSHA letter of interpretation on software-generated OSHA recordkeeping forms at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29.

• OSHA allows employers to keep equivalent forms in electronic formats provided the records contain the same information and are as readable and understandable as the OSHA forms.
• The software-generated forms must be able to produce equivalent output for employee access and government inspection requirements described in the recordkeeping rules and in the software LOI.

If your establishment is required to electronically submit injury and illness data based on the submission thresholds, then the medical removal entries that appear on your OSHA Form 300/300A must be included in that electronic submission. See 1904 and OSHA's enforcement guidance on electronic submission at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

• Establishments meeting the employee-count and industry criteria in the electronic submission rule must submit Form 300A data (and in some cases Form 300 and Form 301 data) to OSHA by the required deadline.
• A medical removal case recorded on your Log affects the totals on Form 300A, which are subject to electronic reporting if your establishment falls within the required categories.

Yes — payment of wages while an employee is medically removed does not change the recording requirement: you must record the medical removal required by an OSHA standard on the OSHA 300 Log, and classify it as days away or restricted work based on how you comply with the removal requirement. See 1904.9(a) and 1904.9(b)(1).

• Employer-paid leave does not turn a removal into a non-recordable event when removal is required by a substance-specific OSHA standard.
• If the removal is due to chemical exposure, remember to check the "poisoning" column per 1904.9(b)(1).

Yes — medical removal cases that meet OSHA recording criteria are recordable and should be supported by the Injury and Illness Incident Report (OSHA Form 301) or an equivalent form as required by Part 1904 recordkeeping rules. See 1904 and OSHA's letter on software-generated forms at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 which explains equivalency requirements for Forms 300/300A/301.

• Maintain the Form 301 (or equivalent) with details about the medical removal, exposure, and treatment.
• Electronic equivalents are acceptable if they include the same information and are as readable and retrievable as the OSHA form per the software LOI.

If the employee is removed in accordance with an OSHA standard's medical surveillance requirement, the case must be recorded; if instead removal does not occur because the employee refuses the medical evaluation, the employer must document the situation and make a good-faith recordkeeping determination. See 1904.9(a) and the general recordkeeping requirement in 1904.

• If the refusal prevents the employer from meeting the medical removal criterion, then there is no hospital-mandated removal to record; however, document the refusal and any related exposure events so you can support your recordkeeping decision.
• If later evidence shows the employee met the medical removal criteria or the employer removed the employee to comply with a standard, then record the case under 1904.9(a).

Record the medical removal on the OSHA 300 Log as required by 1904.9(a) and classify it per 1904.9(b)(1); if the hospitalization meets reporting thresholds (e.g., inpatient hospitalization), you must also follow federal reporting requirements under Part 1904 and any applicable employer reporting rules described in OSHA guidance. See 1904 for overall recording and reporting obligations.

• Hospitalization may trigger both a recordable entry and separate employer reporting obligations — keep medical and exposure documentation together with your injury/illness records.
• If your establishment is required to submit records electronically, include the case in the appropriate Form 300/300A data as described in OSHA’s electronic submission guidance at https://www.osha.gov/laws-regs/standardinterpretations/2024-04-16.

Yes — any employee medically removed under the medical surveillance requirements of an OSHA standard must be recorded on the OSHA 300 Log regardless of whether the standard is chemical or biological. See 1904.9(a).

• If the removal is due to a non-chemical standard that includes medical removal, record it and classify it as days away or restricted per 1904.9(b)(1).
• If the standard involves chemical exposure, also check the "poisoning" column as required by 1904.9(b)(1).

No — the examples in 1904.9(b)(2) are not exhaustive. Many OSHA substance-specific standards include medical removal provisions; lead and cadmium are examples, but other chemical standards may also require medical removal.

• Always check the specific substance standard for its medical removal provisions.
• If a standard contains medical removal language, follow 1904.9(a) to record the case on the OSHA 300 Log.

If the voluntary removal is not recordable under 1904.9(b)(3), you are not required to include it on the OSHA 300 Log; however, any equivalent OSHA Forms 300/301/300A you do maintain electronically must be available for inspection and employee access as required under Part 1904. See 1904 and OSHA’s software-generated forms letter at https://www.osha.gov/laws-regs/standardinterpretations/2025-04-29 for guidance on electronic records and access.

• Equivalent electronic records must be as readable and understandable as OSHA forms and must be producible for government inspection and employee access.
• Keep documentation supporting your decision that the removal was voluntary and occurred before regulatory thresholds were met.

No — your OSHA 300 Log entry must reflect how you actually complied with the medical removal requirement: enter a case as days away or restricted work depending on what the removal involved in practice. See 1904.9(b)(1).

• You cannot inaccurately classify a removal to avoid recording days away; the log must describe the real outcome of the removal (actual days away or actual restricted duty).
• Keep records that document the assignment or absence used to comply with the medical removal requirement in case OSHA requests verification.