29 CFR § 1904.7 — General recording criteria
29 CFR — Labor · OSHA / DOL
29 CFR 1904.7 defines what makes a workplace injury/illness 'recordable' under OSHA's 300 Log system. The criteria are: death, days away from work, restricted work/job transfer, medical treatment beyond first aid (this catches most cases), loss of consciousness, or physician diagnosis of significant work-related condition. First aid alone is NOT recordable — but the line between 'first aid' and 'medical treatment' is precisely defined in 29 CFR 1904.7(b)(5)(ii). Recordable cases must be logged within 7 calendar days. Misrecording (omitting recordable cases or wrongly recording first-aid as non-recordable) is one of the most-cited recordkeeping violations.
Regulation summary
Each employer must record any work-related injury or illness that results in one or more of the following: (a) death; (b) days away from work; (c) restricted work activity or transfer to another job; (d) medical treatment beyond first aid; (e) loss of consciousness; (f) diagnosis of a significant work-related injury or illness by a physician or other licensed health care professional. Each recordable case must be entered on the OSHA 300 Log within 7 calendar days of receiving information that the case occurred.
Who must comply
All employers subject to 29 CFR Part 1904 — generally private-sector employers with 10+ employees in non-partially-exempt industries.
What happens if violated
Recordkeeping violations: typically classified as 'other-than-serious' with penalties up to $16,131 per violation (2025). Patterns of under-recording can escalate to willful violations at $161,323. OSHA Inspector also has the option to audit the OSHA 300 against workers' compensation records, medical bills, and incident reports — discrepancies suggest systemic under-recording.
Implementation checklist
- Train HR / safety staff on the 6 recordability criteria.
- Implement a workflow that captures every work-related injury within 7 days of report.
- Cross-reference workers' compensation claims against the 300 Log monthly.
- Distinguish first-aid (29 CFR 1904.7(b)(5)(ii) list) from medical treatment carefully.
- Capture restricted-work and job-transfer days even when no actual lost time.
- Maintain incident reports / accident investigation records to support 300 Log entries.
- Document close-call near-miss reporting (not recordable but useful for safety improvement).
- Audit 300 Log accuracy quarterly — compare against medical bills, WC claims, supervisor reports.
Common misinterpretations
- Misinterpretation: 'A doctor visit alone is recordable.' Reality: A doctor visit for a work-related injury where the doctor provides FIRST AID only (cleaning, bandage, over-the-counter medication) is NOT recordable. The visit becomes recordable when MEDICAL TREATMENT is provided — prescription medication, sutures, immobilization, etc.
- Misinterpretation: 'A sprain on the way to lunch isn't work-related.' Reality: Work-relatedness includes injuries that occur on the employer's premises (with very narrow exceptions for personal grooming, eating in the cafeteria as a public visitor, etc.). An injury walking in a hallway during work hours is work-related and potentially recordable.
- Misinterpretation: 'First aid kit medication doesn't count.' Reality: 29 CFR 1904.7(b)(5)(ii) defines 14 specific 'first aid' actions. Anything beyond those 14 actions is medical treatment. Common first-aid: tetanus shots, eyewash, simple bandages. Common medical treatment: prescription medications, sutures, splints, IV fluids.
- Misinterpretation: 'Days away counted from the next workday.' Reality: 29 CFR 1904.7(b)(3) counts days away starting from the day AFTER the injury. The day of injury itself does NOT count as 'day away.' For example, injury Monday, returning Thursday = 2 days away (Tuesday + Wednesday).
Frequently asked questions
What makes an injury 'recordable' under 29 CFR 1904.7?
Death, days away from work, restricted work or job transfer, medical treatment beyond first aid, loss of consciousness, or physician diagnosis of significant work-related injury/illness. Any ONE of these makes the case recordable.
What's the difference between first aid and medical treatment?
29 CFR 1904.7(b)(5)(ii) lists 14 specific 'first aid' actions: non-prescription medication at non-prescription strength, tetanus immunizations, cleaning/flushing wounds, wound coverings, hot/cold therapy, non-rigid supports, eye patches, foreign body removal from eye by irrigation/cotton swab, finger guards, massages, fluids for heat stress, etc. Anything BEYOND these is medical treatment.
How quickly must I record a case?
Within 7 calendar days of receiving information that a recordable case occurred. Late recording is a violation.
Are mental health conditions recordable?
Yes — work-related mental illnesses are recordable if they meet the criteria (e.g., physician diagnosis of significant work-related condition). The employee must self-identify a mental illness as work-related for it to enter the OSHA 300 system. Privacy protections apply.
How are days away from work counted?
Starting the day AFTER the injury. The day of injury itself is not counted. Injury Monday, returns Thursday = 2 days away (Tuesday + Wednesday). Cap at 180 days (per 1904.7(b)(3)(iv)) — beyond that, leave as 180 days.
Does an injury on the way to/from work count?
Generally no — commuting is not work-related. Exceptions apply: company vehicle, employer-required travel, business errands during commute.
Cross-references: 29 CFR 1904.4 · 29 CFR 1904.5 · 29 CFR 1904.32 · 29 CFR 1904.35
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