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Is it OSHA recordable?
Six questions, following 29 CFR 1904. A walkthrough, not a ruling. The determination is yours to make and to document.
Based on 29 CFR 1904.4 through 1904.7. Where a case is ambiguous the regulation expects a documented judgment, not a coin toss. Write down the reasoning either way.
What the six questions cover
- Whose log it is. 1904.31: an employee, or a contractor whose day-to-day work you supervise.
- Work-relatedness. 1904.5: an event or exposure in the work environment caused or significantly aggravated it, subject to the listed exceptions.
- A new case. 1904.6: not a continuation of a case already recorded.
- The general recording criteria. 1904.7: death, days away, restricted work or transfer, loss of consciousness, medical treatment beyond first aid, or a significant injury or illness diagnosed by a physician or other licensed health care professional.
Cases recordable by rule
Some cases are recordable under their own sections, whatever the general criteria say. The walkthrough does not ask about them, so check these first.
- Needlesticks and cuts from sharp objects contaminated with another person's blood or other potentially infectious material (1904.8).
- Medical removal under the requirements of an OSHA standard (1904.9).
- A standard threshold shift in hearing that meets 1904.10.
- Tuberculosis infection after exposure at work to a known case of active tuberculosis (1904.11).
Three healthcare examples
- A phlebotomist sticks a finger with a used hollow-bore needle. Recordable under 1904.8, even if the only care given is first aid.
- An aide strains a back lifting a patient, takes a nonprescription pain reliever at nonprescription strength, and returns to full duty. First aid only, so not recordable under the general criteria.
- A physician restricts a nurse from lifting for a week. Recordable: restricted work is one of the general criteria.
The decision guide explains each criterion in more detail, with more healthcare cases. Once you know what is on the log, the OSHA incidence rate calculator turns it into TRIR and DART.
Questions
Is a needlestick always recordable?
A needlestick or cut from a sharp contaminated with another person's blood or other potentially infectious material is recordable under 1904.8. A clean sharp follows the general criteria.
Can first aid make a case recordable?
No. The first-aid list in 1904.7(b)(5)(ii) is complete. A case that needed only first aid is recordable only if it meets another criterion, such as days away or restricted work.
How long do I have to record a case?
Seven calendar days from receiving information that a recordable injury or illness occurred (1904.29(b)(3)).
Is recordable the same as reportable?
No. A reportable case must also be reported to OSHA directly: a work-related fatality within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours (1904.39). Every reportable case is also recordable.