One clinical choice — sutures vs. Steri-Strips — can decide whether a case goes on your 300 Log (1904.7(b)(5)(ii)(D)) — this free decision tree walks the actual 29 CFR Part 1904 criteria one question at a time, so you can screen a case before it goes on (or stays off) your 300 Log. Treatment decisions belong to clinical judgment alone — recordkeeping consequences should never influence what care an employee receives. Pair it with our TRIR & DART calculator and the OSHA first-aid kit requirements guide.
Is this injury OSHA recordable?
Short answer: a work-related 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 a significant diagnosis by a physician or other licensed health care professional (29 CFR 1904.7) — or if it hits one of the special criteria in 1904.8–.11. This tool asks the questions in the order the rule does and returns a screening result with the section citations. It is a screening aid, not a legal determination.
This screener implements the recording criteria of 29 CFR Part 1904 — OSHA's injury and illness recordkeeping rule — built from the criteria as published in the eCFR (current as of August 11, 2026) and condensed for preliminary screening. It walks the same sequence OSHA's own regulation lays out: employee status (1904.31), work-relatedness and its nine exceptions (1904.5), new-case determination (1904.6), the special criteria (1904.8–.11), and the general recording criteria including the complete first-aid list (1904.7). The result is a preliminary screening — the recordkeeping decision belongs to the employer and, where a case is unclear, to a qualified professional or OSHA's own interpretation letters.
Before anything else: did the incident involve a fatality, an in-patient hospitalization, an amputation, or the loss of an eye?
This severity gate is about OSHA's reporting rule (1904.39), which runs on a clock measured in hours and applies to every employer covered by the OSH Act — even ones exempt from keeping a 300 Log. It is asked first so the deadline is not missed while you work through recordability.
Severe-outcome details — what decides the 1904.39 reporting duty
A fatality is reportable only if death occurs within 30 days of the work-related incident; an in-patient hospitalization, amputation, or loss of an eye only if it occurs within 24 hours of the incident (1904.39(b)(6)). “In-patient hospitalization” means a formal admission to the in-patient service for care or treatment — observation or diagnostic testing alone is not reportable (1904.39(b)(9)–(10)). The reporting clock — 8 hours for a fatality, 24 for the others — runs from when you or your agent learns of the event.
Which outcome(s) occurred?
Did it result from a work-related incident?
Did the outcome occur within the reporting window? (fatality: within 30 days of the incident · hospitalization/amputation/eye loss: within 24 hours of the incident — if more than one outcome occurred, answer Yes if ANY of them occurred within its own window)
If hospitalized: was it a formal admission to the in-patient service for care or treatment? (emergency-room observation or diagnostic testing alone does not count)
Did the incident happen in traffic or on public transit? Two reporting exceptions apply here — the case can still be recordable either way (1904.39(b)(3)–(4)).
Was the injured or ill person your employee?
"Employee" includes everyone on your payroll — labor, executive, hourly, salary, part-time, seasonal, migrant — plus temporary, leased, or personnel-supply workers you supervise on a day-to-day basis (1904.31). A contractor's employee supervised day-to-day by the contractor is recorded on the contractor's log. Self-employed individuals are not covered.
Is there an injury or illness at all?
An injury or illness means a new symptom, sign, or condition — a cut, sprain, burn, hearing shift, respiratory condition, and so on — arising from an event or exposure, or a pre-existing condition significantly aggravated by a workplace event or exposure. A near-miss with no injury, or property damage alone, produces nothing to record.
Where did the event or exposure occur?
Location changes how work-relatedness is evaluated — pick the closest fit, then answer the next question with the matching rule in mind.
Is it work-related?
Under 1904.5(a), you must consider the case work-related if an event or exposure in the work environment either caused or contributed to the condition, or significantly aggravated a pre-existing injury or illness. Work-relatedness is presumed for events and exposures in the work environment unless one of the nine exceptions in 1904.5(b)(2) applies — those are the next question.
Does one of the nine 1904.5(b)(2) exceptions apply?
These are the only situations where a case that occurred in the work environment is still not work-related. Check any that apply, then continue. (Condensed from the regulation — read the full text for edge cases.)
If none apply, just continue — the presumption of work-relatedness stands.
Is this a new case?
Under 1904.6, a case is new if the employee has not previously had a recorded injury or illness of the same type affecting the same body part — or had one, recovered completely (all signs and symptoms gone), and a new workplace event or exposure caused them to reappear. Chronic illnesses whose symptoms recur without any new exposure (occupational cancer, asbestosis, byssinosis, silicosis) are recorded only once.
Do any of the special recording criteria apply?
Part 1904 makes four categories recordable on their own terms, before you ever reach the general criteria. Check any that apply, then continue.
If none apply, continue to the general recording criteria.
TB follow-up: is there evidence of a non-work source?
A positive test or diagnosis after occupational exposure is recordable — but 1904.11(b)(2) lets you line out or erase the case if the infection is shown to be non-occupational. (A positive test at a pre-employment physical is not recorded at all — the exposure was not in your workplace, 1904.11(b)(1).)
Hearing-loss follow-up: retest, age adjustment, work-relatedness
1904.10 adds three qualifications: you may age-adjust the current audiogram when determining the STS (Tables F-1/F-2, appendix F of 29 CFR 1910.95) but not when determining whether the total hearing level is 25 dB or more above audiometric zero (1904.10(b)(3)); a retest within 30 days that does not confirm the STS removes the recording requirement, while a confirming retest starts a 7-calendar-day recording clock, and later testing showing the STS is not persistent lets you erase or line out the entry (1904.10(b)(4)); and a physician or other licensed health care professional may determine under the 1904.5 rules that the loss is not work-related (1904.10(b)(6)).
Does the case meet any of the general recording criteria (1904.7)?
Any single one of these makes the case recordable. Check all that apply, then continue.
The complete first-aid list — 1904.7(b)(5)(ii)(A)–(N)
If the only treatment given is on this list, it is first aid — not medical treatment. The regulation states this list is complete: anything beyond it is medical treatment. The professional status of the provider is irrelevant — these treatments are first aid even when a physician gives them, and treatment beyond this list is medical treatment even when a non-physician gives it.
- Non-prescription medication at nonprescription strength (a PLHCP recommendation to use a non-prescription medication at prescription strength is medical treatment)
- Tetanus immunizations (other immunizations, such as hepatitis B or rabies vaccine, are medical treatment)
- Cleaning, flushing, or soaking wounds on the surface of the skin
- Wound coverings — bandages, gauze pads, butterfly bandages, Steri-Strips (sutures, staples, and other wound-closing devices are medical treatment)
- Hot or cold therapy
- Non-rigid means of support — elastic bandages, wraps, non-rigid back belts (devices with rigid stays or designed to immobilize a body part are medical treatment)
- Temporary immobilization devices used while transporting an accident victim — splints, slings, neck collars, back boards
- Drilling a fingernail or toenail to relieve pressure, or draining fluid from a blister
- Eye patches
- Removing foreign bodies from the eye using only irrigation or a cotton swab
- Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
- Finger guards
- Massages (physical therapy or chiropractic treatment are medical treatment)
- Drinking fluids for relief of heat stress
Also not medical treatment (1904.7(b)(5)(i)): visits to a PLHCP solely for observation or counseling, and diagnostic procedures such as x-rays and blood tests, including prescription medications used solely for diagnostic purposes.
If no criterion is checked, confirm one of the following — an empty checklist is not treated as a “no” on its own:
How this tool works
Every question, threshold, and citation in the tree is drawn from a single source: 29 CFR Part 1904, OSHA's recording and reporting rule, as published in the eCFR. The tool mirrors the regulation's own sequence — the severity gate first because 1904.39's reporting clock (8 hours for a fatality, 24 for an in-patient hospitalization, amputation, or eye loss) runs independently of recordability and applies to every covered employer; then coverage, work-relatedness with its nine exceptions, new-case determination, the four special criteria, and finally the general criteria with the complete first-aid list. The criteria are condensed and simplified for screening, not reproduced clause-for-clause — consult the complete regulation and OSHA’s interpretations for edge cases; where the rule is genuinely gray, the tool says so and points to OSHA's interpretation letters.
| Source | What it provides | Date |
|---|---|---|
| 29 CFR Part 1904 — Recording and Reporting Occupational Injuries and Illnesses (eCFR) | Every criterion in this tree: coverage (1904.31), work-relatedness and exceptions (1904.5), new cases (1904.6), general criteria and the first-aid list (1904.7), special criteria (1904.8–.11), forms and deadlines (1904.29, 1904.32, 1904.33), reporting (1904.39), electronic submission (1904.41) | Current as of Aug. 11, 2026 |
| OSHA standard interpretation letters | The agency's own answers for gray-area cases the regulation text does not settle | Ongoing; linked from every result |
Worked example
A machine operator slices a forearm on a sheet-metal edge. The clinic closes the cut with three sutures; the operator is back at full duty the next day. Walking the tree:
- Severity gate: no fatality, in-patient hospitalization, amputation, or eye loss → no 1904.39 report.
- Employee? Yes — on payroll (1904.31).
- Injury? Yes — a laceration.
- Work-related? Yes — an event in the work environment caused it (1904.5(a)); none of the nine exceptions fit.
- New case? Yes — never previously recorded (1904.6(a)(1)).
- Special criteria? None — no contaminated sharp, no medical removal, no STS, no TB.
- General criteria: sutures are a wound-closing device, which 1904.7(b)(5)(ii)(D) expressly places beyond first aid → medical treatment beyond first aid → screens as likely recordable. No days away, no restriction — so on the 300 Log it takes a check in the box for cases where the employee received medical treatment but remained at work and was not transferred or restricted (1904.7(b)(5)), entered within 7 calendar days of learning of it (1904.29(b)(3)).
The arithmetic of the counterfactual matters just as much: had the same cut been closed with Steri-Strips and nothing else, item (D) of the first-aid list covers it — first aid only, no other criterion, not recordable. One clinical choice, zero vs. one entry on the log — which is why the first-aid list is reproduced in full inside the tool. Medical treatment must be based solely on the employee’s clinical needs; recordkeeping consequences should never influence treatment decisions. The list classifies a completed case — it is not a menu for managing the log.
What the inputs mean
Work environment — "the establishment and other locations where one or more employees are working or are present as a condition of their employment," including the equipment and materials the employee uses (1904.5(b)(1)).
Injury or illness — a new sign, symptom, or condition resulting from an event or exposure; the tree treats it as the trigger for everything downstream.
Work-related — an event or exposure in the work environment caused, contributed to, or significantly aggravated the condition (1904.5(a)). "Significantly aggravated" has its own test at 1904.5(b)(4): the workplace event produced death, loss of consciousness, days away/restriction/transfer, or medical treatment that would not otherwise have occurred.
New case — not previously recorded for the same type and body part, or fully recovered and re-triggered by a new workplace event (1904.6).
Medical treatment — "the management and care of a patient to combat disease or disorder," excluding observation/counseling visits, diagnostic procedures, and first aid (1904.7(b)(5)(i)).
First aid — the complete 14-item list at 1904.7(b)(5)(ii); anything beyond it is medical treatment, no matter who provides it. For what belongs in the cabinet itself, see our first-aid kit requirements guide and the first-aid kits we have reviewed.
Restricted work — the employee is kept from one or more routine job functions or a full workday, either by the employer or by a PLHCP recommendation (1904.7(b)(4)(i)).
PLHCP — physician or other licensed health care professional: someone whose legally permitted scope of practice (license, registration, or certification) allows them to independently perform, or be delegated, the activities in the rule (1904.46).
STS (Standard Threshold Shift) — a change in hearing threshold, relative to the employee's baseline audiogram, averaging 10 dB or more at 2000, 3000, and 4000 Hz in one or both ears (1904.10(b)(1), referencing 29 CFR 1910.95(g)(10)(i)).
Days-away counting — begin counting the day after the injury or illness began; count calendar days, including weekends, holidays, and days the employee was not scheduled to work; you may cap the total at 180 calendar days (1904.7(b)(3)).
The forms and deadlines behind the log
A recordable case generates paperwork on a clock (1904.29): the OSHA 300 Log entry and a 301 Incident Report (or equivalent, such as a suitable insurance form) within 7 calendar days of receiving information that a recordable case occurred. At year end, the 300A Summary totals the log; a company executive — an owner (only if the company is a sole proprietorship or partnership), a corporate officer, the highest-ranking company official working at the establishment, or that person's immediate supervisor — must certify it (1904.32), and it must be posted from February 1 through April 30 of the following year. The 300 Log, 301 reports, privacy case list, and annual summaries are kept for 5 years after the year they cover, and the stored 300 Logs must be updated with newly discovered cases and classification changes during that period (1904.33).
Who is exempt from recordkeeping — and who never is
Two partial exemptions exist. Size: if your company had 10 or fewer employees at all times during the last calendar year — peak employment, entire company, not per-site — you need not keep OSHA injury and illness records unless OSHA or the BLS tells you in writing to do so (1904.1(a)(1), 1904.1(b)). Industry: establishments classified in the low-hazard industry groups listed in appendix A to subpart B of Part 1904 are likewise partially exempt (1904.2). But both exemptions are partial for a reason: the 1904.39 reporting duty — fatality within 8 hours; in-patient hospitalization, amputation, or loss of an eye within 24 hours — applies to all employers covered by the OSH Act, exempt or not.
Electronic submission (1904.41)
Three categories of establishments must also submit data electronically through OSHA's Injury Tracking Application, by March 2 of the year after the calendar year covered: establishments with 20–249 employees in an industry listed in appendix A to subpart E submit their 300A annually; establishments with 250 or more employees that are required to keep records submit their 300A; and establishments with 100 or more employees in an industry listed in appendix B to subpart E submit information from their 300 Log and 301 reports as well. Employee names and certain identifying fields are excluded from the 300/301 submission. The requirement applies in State Plan states too.
Limitations
- Screening only. The output is "screens as likely recordable / likely not" — the recordkeeping determination belongs to the employer, and gray cases belong to a qualified professional or OSHA's interpretation letters. It is not legal advice and not a determination.
- The nine exceptions are compressed. Each 1904.5(b)(2) exception carries qualifying language (notes on contaminated food, contagious diseases, and the mental-illness PLHCP opinion, among others) — read the full regulation text for edge cases.
- Travel and home-work cases have their own rules (1904.5(b)(6)–(7)) that this screen does not walk through question-by-question.
- State Plan states operate their own programs and may impose stricter or additional requirements.
- Interpretation letters govern gray areas — where the text is ambiguous, OSHA's published interpretations control, not this tool.
- Privacy cases are not covered. The special handling for privacy concern cases (1904.29(b)(6)–(9)) — name withholding and discretion in descriptions — is outside this screen.
- Re-screen when facts change. A case screened "not recordable" today becomes recordable the day a criterion is met later (e.g., a prescription is written next week).
Educational screening aid only. This tool paraphrases 29 CFR Part 1904 (eCFR, current as of Aug. 11, 2026) and is not a substitute for the regulation text, an OSHA interpretation, or professional judgment. WC Safety holds no safety certification. The recordkeeping decision — and liability for it — remains the employer's.
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Frequently asked questions
Is first aid recordable?
No — if the case involves only treatment from the complete 14-item first-aid list at 1904.7(b)(5)(ii) and meets no other general or special criterion, it is not recordable. The list is closed: the regulation states it is a complete list, so anything beyond it is medical treatment.
Is every emergency-room visit recordable?
No. Visits to a physician or PLHCP solely for observation or counseling, and diagnostic procedures such as x-rays and blood tests (including prescription medications used solely for diagnostic purposes), are expressly excluded from medical treatment (1904.7(b)(5)(i)(A)–(B)). An ER trip that ends in first aid and a clean x-ray triggers nothing by itself.
A prescription was recommended but the employee never took it — recordable?
Yes. If a physician or other licensed health care professional recommends medical treatment, the case must be recorded even if the employee does not follow the recommendation (1904.7(b)(5)(v)). The same logic applies to recommended days away: they are recorded whether or not the employee stays home.
Are "recordable" and "workers'-comp compensable" the same thing?
No. OSHA recordkeeping under Part 1904 and workers' compensation are separate systems with different definitions — a case can be recordable and not compensable, or compensable and not recordable. Nothing in Part 1904 affects a workers' compensation determination.
Who decides in a gray case?
The employer makes the entry — but where the rule text does not settle a fact pattern, OSHA's published standard interpretation letters govern, and a qualified safety or occupational-health professional is the right escalation. This tool is a screen, not the decision.
Does recording a case mean we violated an OSHA rule?
No. Recording is a tracking duty — the log is a census of work-related injuries and illnesses, not an admission of fault or of any violation. Citations arise under separate standards through inspections, not from log entries themselves.
Do temporary workers go on my log or the staffing agency's?
Whichever employer supervises the worker day-to-day records the case — and only that employer, so the case is recorded exactly once (1904.31). If you direct the temp's daily work, the case goes on your 300 Log even though the agency runs payroll.
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Built and reviewed by Steven Eaton, WC Safety. We curate and review industrial PPE against ANSI, NIOSH and OSHA standards. The decision logic on this page paraphrases 29 CFR Part 1904 as published in the eCFR (current as of Aug. 11, 2026) and is provided for educational use.
Our methodology
This decision tree implements the recording criteria of 29 CFR Part 1904 as published in the eCFR (current as of Aug. 11, 2026), in the regulation's own order, with every threshold cited to its section — and says plainly where the rule leaves gray areas to OSHA's interpretation letters. Authoritative duties live at OSHA regulations and the current rule text at the eCFR. We hold no safety certification, and this tool is not a substitute for professional judgment.
Why trust this page
WC Safety is an independent review site with no products of its own — nothing here is stocked, warehoused or shipped by us. Purchase links go to Amazon and earn an affiliate commission at no extra cost to you. This free tool is informational — it supports, and never replaces, a written program, a hazard assessment, or evaluation by a qualified safety professional.
Researched and written by Steven Eaton, editor of WC Safety. Steven holds no safety certification; this page implements published government regulation — 29 CFR Part 1904 as published in the eCFR, current as of August 11, 2026 — with section citations throughout and the gaps left to OSHA interpretation letters marked. Last reviewed August 2026.